Privacy Policy

1. Introduction

Zoom Games Ltd ("Zoom Games", "we", "us", "our") makes ZoomXI, a football quiz game in which users identify professional footballers from progressively revealed, zoomed-in photographs. This policy explains how we collect, use, and protect personal information across:

• the website at zoomxi.app (the "Website"); and
• the ZoomXI mobile application for iOS and Android (the "App"),

together, "the Services". Please read this policy alongside our Terms of Use.

2. Who We Are

Zoom Games Ltd is the data controller responsible for your personal information. We are a company registered in England and Wales under company number 17259532, with our registered office at:

17 Eaton Park Road, Cobham, England, KT11 2JJ

For any privacy question, or to exercise any of the rights described below, contact us at privacy@zoomxi.app.

3. Information We Collect

3.1 Information We Collect via the Website

• Contact form and enquiry submissions — name, email address, and the content of your message.
• Technical and usage data collected automatically — IP address, browser and device type, pages viewed, referral source, and approximate location derived from your IP address, via cookies and similar technologies (see Section 7).

3.2 Information We Collect via the App

• Account information — such as your name, username, email address, or the profile details shared with us when you sign in via a third-party provider (e.g. Google or Apple Sign-In).
• Gameplay data — quiz answers, scores, streaks, achievements, and your in-app currency balance.
• Purchase data — records of in-app purchases. Payment card details are collected and processed by Apple's App Store or Google Play, not by us; we receive only confirmation of the transaction (e.g. product purchased, amount, date).
• Voice input data — if you use the App's voice-answer feature, audio you speak is processed in real time to convert it to text so your answer can be matched against footballers' names. This audio is not recorded or retained by us — see Section 9 for the third party involved.
• Device and diagnostic data — device model, operating system version, app version, language settings, and crash/error logs, together with analytics events used to understand how the App is used (e.g. which screens are visited, session length), via an analytics service.
• Approximate location — we do not request GPS or other precise device location. We derive an approximate region from your IP address, which we may use for features such as regional leaderboards.
• Push notifications — if enabled, we use these to send you gameplay reminders and updates (e.g. daily challenge alerts); you can turn them off at any time in your device settings.

4. Our Legal Bases for Processing (UK and EU GDPR)

Where UK or EU data protection law applies, we rely on the following legal bases:

• Contract — to create your account, operate the quiz and in-app currency, and process purchases you request.
• Legitimate interests — to keep the Services secure, understand and improve how they're used, and — as explained in Section 5 — to display licensed footballer photographs as the core mechanic of the quiz.
• Consent — for non-essential cookies, marketing communications you've opted in to, and microphone access for the voice-answer feature, which you can withdraw at any time through your profile or device settings.
• Legal obligation — e.g. retaining records needed for tax and accounting purposes.

5. Footballer Photographs and Information Used in the Quiz

The quiz mode at the heart of ZoomXI works by progressively revealing a zoomed-in photograph of a professional footballer for users to identify, together with factual hint information such as the footballer's name, nationality, and club. All footballer photographs used in the quiz are used under a copyright licence from IMAGO (imago-images.com), a professional sports and press photo agency.

No endorsement: other than co-founder Peter Crouch, the footballers who appear in the quiz have not endorsed or sponsored ZoomXI, and their inclusion is solely for identification and entertainment purposes. Nothing in the Services should be read as implying any partnership, sponsorship, or affiliation between Zoom Games Ltd and any other footballer, club, league, or players' association.

5.1 Legal Basis

• We rely on legitimate interests as the lawful basis for this processing.
• The hint information (name, nationality, club) is basic, publicly available professional information about the footballer, sourced from public reporting; it is not special category data under UK GDPR.
• We do not carry out any facial recognition or other biometric processing — we display licensed photographs and match your answer against the footballer's name, nothing more.
• Footballer photographs remain in the quiz for as long as they form part of the game's content and we hold a licence covering their use.

5.2 Requests Concerning a Photograph's Use

If you are a professional footballer featured in the quiz, or someone authorised to act on your behalf, and you have concerns about the use of your photograph or hint information, you can contact us at privacy@zoomxi.app with:

• your name and (if applicable) your role acting on the footballer's behalf, with evidence of that authority;
• which footballer and photograph the request relates to; and
• the nature of your concern and what outcome you're asking for.

We will acknowledge your request within 5 working days and review it individually. Depending on the outcome, we may remove the photograph from the quiz, restrict how it's used, or explain why we consider our use is justified. This sits alongside, and does not limit, the rights set out in Section 13, which apply to footballers featured in the quiz in the same way as they do to our users.

6. Use of Peter Crouch's Image and Likeness

Peter Crouch, a co-founder of ZoomXI, has given his permission for his image and likeness to be used in ZoomXI's advertising and marketing materials.

7. Cookies and Similar Technologies (Website)

The Website uses cookies and similar technologies to:

• operate core site functionality ("strictly necessary" cookies, which do not require consent); and
• understand site traffic and usage, via an analytics service.

Where required, we ask for your consent to non-essential cookies via a cookie banner when you first visit the Website, and you can change your preferences at any time through that banner or your browser settings. See our Cookie Policy for more detail.

8. How We Use Your Information

• to provide, operate, and maintain the Services, including your account, quiz progress, and in-app currency balance;
• to process in-app purchases and provide customer support;
• to detect, investigate, and prevent fraud, abuse, or security incidents;
• to understand usage patterns and improve the Services (including new quiz content and features);
• to comply with our legal obligations;
• to send you marketing communications about ZoomXI, where you have opted in to receive them via your profile settings — you can unsubscribe at any time; and
• to create aggregated or anonymised data, which no longer identifies you, for purposes such as product analytics or public statistics.

9. Sharing Your Information

We share personal information with the following categories of recipient, each acting as a processor on our instructions or as an independent controller of their own service:

• Apple Inc. and Google LLC — app distribution, sign-in (OAuth), and in-app purchase processing through the App Store and Google Play. Payment card details are handled entirely by Apple/Google; we do not receive or store them.
• Google Cloud — speech-to-text processing for the voice-answer feature. Audio is processed to produce a text match and is not stored or retained.
• an analytics service — to help us understand how the Website and App are used;
• a cloud hosting provider — to store and process account and gameplay data securely;
• professional advisers (legal, accountancy) where necessary to run our business; and
• law enforcement, regulators, or other third parties where we are required to do so by law, or to protect our rights or the safety of our users.

Where you use features such as leaderboards, your username and score may be visible to other users of the App.

We do not sell your personal information.

Our Services may also link to third-party websites, such as the App Store or Google Play; those sites have their own privacy practices, which this policy does not cover.

10. International Data Transfers

Some of the providers listed above (including Apple and Google) may process personal information outside the UK and European Economic Area, including in the United States. Where we transfer personal information internationally, we rely on recognised safeguards such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or an applicable adequacy decision, to ensure your information remains protected.

11. Data Retention

We keep personal information for as long as your account is open, and enquiries sent through the Website for as long as needed to deal with them. To delete your profile and associated data, contact privacy@zoomxi.app. We may need to retain certain information to meet our legal, accounting, or dispute-resolution obligations.

12. Children's Privacy

ZoomXI is a football quiz suitable for all ages, but it is not directed at children under 13, and you must be 13 or over to create an account. In some countries the minimum age may be higher, depending on local law. We collect no more personal information than the Services need to work, and we do not use children's data for profiling or targeted advertising.

We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact privacy@zoomxi.app and we will take appropriate steps to remove it.

13. Your Rights

Subject to applicable law, you have the right to: access the personal information we hold about you; request correction of inaccurate information; request erasure; restrict or object to our processing (including processing based on legitimate interests); request portability of your data; and withdraw consent at any time where we rely on it. To exercise any of these rights, contact us at privacy@zoomxi.app. We aim to respond within one month of your request; this may be extended by a further two months for complex requests, in which case we'll let you know why. UK users also have the right to complain to the Information Commissioner's Office (ico.org.uk); EEA users may complain to their local supervisory authority.

14. Security

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

15. Changes to This Policy

We may update this policy from time to time. Where we make material changes, we will take reasonable steps to notify you (for example, via the App or an in-app notice) before the change takes effect. The "Last updated" date at the top of this policy shows when it was last revised.

16. Contact Us

Zoom Games Ltd

17 Eaton Park Road, Cobham, England, KT11 2JJ

Company number: 17259532

privacy@zoomxi.app