Objective and Scope
Zwooosh / Zwooosh.com (“we”, “us”, “our”, “Zwooosh”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.
We are continuously updating, improving and expanding the range of our services, which may result in change of this policy more often, so please refer back to it periodically. While accessing the Company website/Application, you provide your express consent to collection, storage, and use of the personal information you provide (including any changes thereto as provided by you) for any of the services that we offer.
However, we respect the privacy of the user data and are committed to reasonably protect it in all respects as we would protect our own information.
- Collection and Use of Personal Information
Personal information (PI) – means any information relating to an identified or identifiable living person (‘data subject’ herein referred as ‘you/your’). In particular using a common identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The Company respects the privacy of the users of the Services and is committed to reasonably protect it in all respects. The information about the user as collected by the Company is:
- Information you provide to us
Information Collected when you use our Website
Many of our services require you to register/sign up for an account on Zwooosh. When you do, we will ask for personal information, to continue to interact with you and to continue providing you the Services. Information that we collect include, but not limited to –
- Your name
- Email address
- Mobile/telephone number(s)
Information Collected when you use our Mobile Application
When you download our mobile application (related to our various services) we collect the below information, but not limited-
- Device ID
- Contact Number
- Date of Birth
- Citizens / Residents
To add certain content, like pictures, you may allow us to access your camera or photo album
Information you provide to us voluntarily
We may collect additional information at other times, when you provide feedback(s), modify your content or email preferences, respond to surveys, or communicate with us by posting a comment on our website/application or asking us a question through or e-mail. This information may include personal information such as, but not limited to, your name, e-mail id, mobile number, comment, message etc.
While subscribing to our paid services, we or our payment gateway provider may collect some of the information provided by you viz. your name, purchase address or billing information, including your credit/debit card number, expiration date etc. However, we endeavor and make every reasonable effort to protect such valuable and sensitive information from any kind of leakage. Every attempt shall be made to limit the use of such information for which it is provided.
Retention of personal information:
Because of the way we operate and maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
- Information Automatically Collected/Tracked while Navigation Cookies
To improve the responsiveness of the “Services” for our users, we may use “cookies”, (a small text file that may be used, for example, to collect your information about Website/Application activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a user) or similar electronic tools to collect information to assign each visitor a unique, random number as a User Identification (“User ID”) to understand the user`s individual interests using the identified computer. Our advertisers may also assign their own cookies to your browser(s) (if you click on their ads), a process that we do not control. We receive and store certain types of information whenever you interact with us via website(s), Application(s) or Services through your computer/laptop/notebook/ mobile/tablet/pad/handheld device or any other electronic device capable of connecting to the internet.
You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your original user ID and password to gain access to certain parts of the Website/application and some sections/features of the site/application may not work.
Log File Information
We automatically collect limited information about your computer`s connection to the Internet, mobile number, including, but not limited to, your IP address, browser software, operating system types; click stream patterns; and dates and times that our site is accessed, whenever you visit(s) our website(s), application(s) or services.
We may use “clear GIFs” (Web Beacons) when you use our websites, to track the online usage patterns in an anonymous manner, without personally identifying the user. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by them. We also collect information from you passively using Google Analytics and Google search console for collecting information about your usage of our website.
- Inferred Information through usage and log data
We may collect and track certain information about you based upon your behaviour on the Zwooosh services We use this information for conducting internal research on our users` demographics, devices, interests, and behaviour to better understand, protect and serve our users.
We may also collect your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
- To evaluate your interest for various genres of content, services, offers;
- To perform analytics and conduct customer research, to determine your interest, for identifying content that generates sales and to analyse traffic patterns.
If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Zwooosh services, we may collect and store such information.
- Information obtained from other Sources
We may receive information about you from other online sources. We may add it to our account information system and treat it in accordance with this policy. If you provide information to the platform provider or other partner to whom we provide services, your account information including, but not limited to, your name, email ID, may be passed on to us. We may obtain updated contact information(s) from third parties in order to correct our records and fulfil the Services or to communicate with you or share the information with any third party.
If you link, connect or login to your Zwooosh services account with a third party service (such as, example Google or Facebook), they may send us information such as your registered e-mail id and public profile information from the service as stated above.
In case you choose to decline to submit personal information on the Application/Websites, we may not be able to provide certain services on the Application/Websites to you. We will make reasonable efforts to notify you of the same at the time of opening your account. In any case, we will not be liable and or responsible for the denial of certain services to you for lack of you providing the necessary personal information.
- Processing of personal information
We will only collect and process personal data about you where we have a lawful basis. Lawful basis on which we would process our personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with services (For e.g. processing your information by our group companies/affiliates).
- We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. When showing you tailored ads, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health.
- Send notification(s) to you on your handheld devices (To turn off the notifications, please visit your account settings).
- Communicate with you concerning our service (for example by email, push notifications), so that we can send you news about Zwooosh, details about new features and content available on the Zwooosh Services, promotional announcements, marketing purposes and surveys, other services of Zwooosh affiliates and to assist you with operational requests such as password reset requests.
- Improve our website/application and its content to provide better features and services
- Conducting market research and surveys with the aim of improving our products and services.
- Preventing, detecting, investigating and prosecuting crimes (including but not limited to fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks
- Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings.
- Our automated systems analyse your content to provide you customised search results, recommendations and specific promotions and offers
- To help advertisers understand our audience and confirm the value of advertising on our websites or applications, (however it is usually in the form of aggregated statistics on traffic to various pages within our site)
- Allow you to participate in interactive features offered through our Services
- Sharing with our customer support team to resolve your queries/concerns related to your rights or services provided to you
III. Third party services
Third parties provide certain services available on Zwooosh. Zwooosh may provide information, including Personal Information that Zwooosh collects on the Website/Application to third-party service providers to help us deliver programs, products, information, and services. Service providers are also an important means by which Zwooosh maintains its Website/Application and mailing lists. Zwooosh will take reasonable steps to ensure that these third-party service providers are obligated to protect Personal Information on Zwooosh’s behalf.
Zwooosh does not intend to transfer Personal Information without your consent to third parties who are not bound to act on Zwooosh behalf unless such transfer is required for legal purposes or for providing relevant services. Similarly, it is against Zwooosh’s policy to sell Personal Information collected online without consent.
When you are in a relationship with Zwooosh, your personal information may be transferred to European Economic Area (EEA) or outside EEA, for the purposes mentioned in this policy or to their local service providers for support in the pursuance of such purposes. Transfers to EEA or outside EEA are covered by standard data protection laws.
We present information to our advertisers to help them understand our audience and confirm the value of advertising on our website/application. It is usually in the form of aggregated statistics on traffic to various pages within our site/application. When you register with Zwooosh, we contact you from time to time about updating your content to provide the users such features that we believe may benefit you.
We use third-party advertising companies to serve ads when you visit our website/application. These companies may use information (such as but not limited to photos/media/files on your device, location, audio about your visits to this and other websites/applications in order to provide advertisements about goods and services of interest to you. However, we do not store this data in our environment.
Zwooosh does not provide any personal information to the advertiser when you interact with or view a targeted ad. However, by interacting with an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.
To use the Site/Application you agree that you must be the minimum age (described in this paragraph below) or older.
The minimum age for these purposes shall be 16, however if local laws require that you must be older in order for Zwooosh to lawfully provide the services in the Site/Application to you then that older age shall apply as the applicable minimum age. In all jurisdictions outside the European Union, if you are under the age of 18 or the age of majority in your jurisdiction, you must use Zwooosh under the supervision of your parent, legal guardian or responsible adult.
- Information Sharing
We restrict access to your Personal Information to employees who we believe reasonably need to know/or that information in order to fulfill their jobs to provide, operate, develop, or improve our products or services.
Zwooosh does not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services you`ve requested, when we have your permission, or under the following circumstances:
- We provide the information to trusted partners who work on behalf of or with ‘Zwooosh’ under confidentiality agreements. These companies may use your personal information to help Zwooosh communicate with you about offers from Zwooosh and our marketing partners. However, these companies do not have any independent right to share this information.
- We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
- Zwooosh works with vendors, partners, advertisers, and other service providers in different industries and categories of business. For more information regarding providers of products or services, please refer to the section “Third party services” of this policy.
- Retention of personal information
Your personal information processed by Zwooosh are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal information are processed in line with legal, regulatory, contractual or statutory obligations as applicable.
At the expiry of such periods, your personal information will be deleted or archived to comply with legal/contractual retention obligations or in accordance with applicable statutory limitation periods.
To the extent permitted by law, Zwooosh may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
VIII. Your Controls and Choices (As applicable under General Data Protection Regulation – GDPR) Compliance
- Accessing and Rectifying your personal information
When you use the services on our Website/Application (or any of its sub sites), we make reasonable efforts to provide you, as and when requested by you, with access to your personal information and shall further ensure that any personal information or sensitive personal data or information found to be inaccurate or deficient shall be corrected or amended as feasible. We ask individual users to identify themselves and the information requested to be accessed or corrected before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, requiring disproportionate technical effort, jeopardizing the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. You can make such requests by sending us an e-mail.
- Right to Rectification
You have the right for inaccurate or incomplete data we hold to be updated. You shall have the right to obtain from Zwooosh without undue delay the rectification of inaccurate personal information concerning you.
- Data Erasure
We retain your personal information as long as necessary for us to provide services to you or you ask us to not retain your data. If you no longer want us to use your information then you can request that we erase your personal information and close your Zwooosh services account. Please note that if you request for the erasure of your personal information;
- We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Zwooosh Services account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Information you have shared with others (e.g., comments, reviews) may continue to be publicly visible on the Zwooosh services, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
- Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
If you have any complaints regarding processing of your personal information you may contact our privacy officer at firstname.lastname@example.org with ‘Privacy Officer’ or ‘Grievance Officer’ marked in the Subject for grievance and redressal. You have the right to complain about the data processing activities carried out by Zwooosh before the competent data protection authorities.
- Security and Compliance with Laws
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. All information gathered is securely stored within the Company controlled database. The database is stored on servers secured behind a firewall on the cloud; access to the servers is password-protected and is strictly limited. However, as effective as our security measures are, no security system is impenetrable. If you know or have reason to believe that your Zwooosh services account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us.
- Social Media
Zwooosh operates channels, pages and accounts on some social media sites to inform, assist and engage with you. Zwooosh monitors and records comments and posts made on these channels about Zwooosh in order to improve its products and services.
Please note that you must not communicate with Zwooosh through such social media sites the following information:
- Sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person`s sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number ;
- Excessive, inappropriate, offensive or insulting information towards individuals.
Zwooosh is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. Zwooosh is only responsible for its own use of the personal data received through such sites
- Changes in the Policy
Zwooosh reserves the right to update, change or modify this policy at any time. The policy shall come to effect from the date of such update, change or modification.
XII. Contact Information
Zwooosh shall not be liable for any loss or damage sustained by reason of any disclosure (inadvertent or otherwise) of any information concerning the user`s account and / or information relating to or regarding online transactions using credit cards / debit cards and / or their verification process and particulars nor for any error, omission or inaccuracy with respect to any information so disclosed and used whether or not in pursuance of a legal process or otherwise.
Any other personal information shared by you which is not asked by Zwooosh during registration, either mandatorily or optionally; accounts to willful and intentional furnishing; and Zwooosh will not be liable for breach of such information.