PRIVACY POLICY
Last updated: May 30, 2022
W
elcome to the E-zevis Privacy Policy (“The Policy”)! This explains how E-zevis collect, store, protect, and share your information, and with whom we share it. We strongly recommend you read this in addition to our Terms and Conditions of Use.
In the process of enjoying the E-zevis mobile application (including the web version) (“Web App”), our websites (such as Ezevis.com) or using our digital products and services (such as our competitions or surveys) (together, referred to in this Privacy Policy as our “Sites”), we collect some information about you. In addition, you may choose to use the App or Sites to share information with other users, including your family, friends and contacts (“Users”). We may also need to share your information sometimes.
The E-zevis App and E-zevis websites are global, and your information will be sent to and used in the United States regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!
About Us
The E-zevis App and E-zevis websites are operated by the “Shenaza Inc,” (also referred to in this policy as “we” or “us”) which includes Shenaza Inc., E-zevis, Afrikanmeet, Zevmob, and Gozevis all of which are controllers of personal information collected and processed through the E-zevis App and E-zevis websites. We can be reached by email on data@ezevis.com or by mail at
1455 NW Leary Way,
Suite 400,
Seattle, WA 98107-5138, USA.
1. COLLECTION OF INFORMATION.
Registration Information
When you download the E-zevis App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:
• Name;
• Email address;
• Mobile number;
• Photographs;
• Location; and
• Login information for social media accounts that you connect to your E-zevis Account (this could include your Facebook, Google, and Apple accounts). For more information about this, see “Linking other Accounts to E-zevis” in section 7 below.
When you’re registered, you will be able to review and change this information at any time just by logging in to E-zevis (other than your location (which, if you have given E-zevis access to your location in your device settings, is automatically updated based on the location of your device)). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.
The information we collect helps to enhance the E-zevis App and verify our Users (robots are not welcome!). Registration Information such as your name, your rating, and profile picture may be visible to other Users who view your profile page.
For Users who are California residents, the data we may collect falls within the following categories of “personal information”, as defined by the California Consumer Privacy Act (CCPA):
A. Identifiers, such as name and location;
B. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
D. Commercial information, such as transaction information and purchase history;
E. Biometric information;
F. Internet or network activity information, such as browsing history and interactions with our Sites and App;
G. Geolocation data, such as mobile device location;
H. Audio, electronic, visual and similar information, such as photos and videos;
I. Professional or employment-related information, such as work history and prior employer;
J. Non-public education information; and
K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Profile Information
We recommend and encourage all users to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.
When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on E-zevis.
Profile Verification Information (Including Biometric Information)
For safety and security and to ensure you have the best possible user experience, we require Users to verify their accounts and might ask for your phone number, email address and, in some instances, we might also ask that you carry out photo verification. We want to make sure you are not a robot! And we also want to avoid fake E-zevis accounts being created which can be used for malicious activities and cybercrime – they threaten the E-zevis platform and users of the E-zevis platform. This verification might be required by us for the prevention of fraud.
If you are required to verify your profile photo, we will scan each photo that you submit. The scan may include the use of facial recognition technology so that we can compare the photo you submit to your profile photo, to help ensure that you are who you say you are. We do not add the verification photos to your profile. We retain the scans so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first. After the applicable retention period expires, we take commercially reasonable steps to permanently and securely delete the scans from our systems.
Subscriptions
Subscription programs involving the E-zevis may be available to you through the Apple and Google platforms. These platforms will charge you an automatic recurring subscription fee and the platform’s payment terms will apply. Please review the appropriate platform’s payment and subscription terms for additional information.
A platform subscription will continue unless and until you cancel your subscription or the platform terminates it. You must cancel any platform subscription before it renews each billing period, otherwise, payment of the next billing period’s subscription fees will be taken automatically via your chosen platform payment method.
You may cancel platform subscription services at any time directly through the relevant platform. In the Apple App Store, you can find the option to cancel by viewing your Apple ID in iTunes or the App Store and then selecting the “Subscriptions” option. In the Google Play Store, you can find the option to cancel in your Google Play Store account.
Geolocation Information
If you have given E-zevis access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the E-zevis App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the listings of other swappers who are near you.
If you have given E-zevis access to your location, but wish to turn this off, you can do so by the following methods:
1. iPhone app — settings, privacy, location services, E-zevis
2. Android — settings, location, E-zevis, permissions, location
Device Information
We may collect information about your device when you use the E-zevis App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this policy.
Links
We may keep track of how you interact with links available on E-zevis including third party services by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
E-zevis Success Stories, Surveys and other Contributions
From time to time, we may run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to provide feedback, a testimonial or take part in marketing campaigns (for example, if you let us know that you have found a match for your item on the App, we may contact you to ask if you would be happy to feature in advertising for E-zevis). Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If you do not wish to be reached out to take part in a survey or marketing campaign, please contact our Customer Support Team via email at contact@ezevis.com.
When you Contact Customer Support
If you contact our Customer Support team via email, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you) for 10 years after deletion of your account.
Cookies and similar technologies
When you visit our Sites or when you use the E-zevis App, we may collect personal data from you automatically by using cookies or similar technologies. A cookie is a small file that can be placed on your device or browser that allows us to recognize and remember you.
If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.
2. USE OF YOUR INFORMATION.
Our main goal is to ensure your experience on E-zevis is an enjoyable one and you don’t end up getting frustrated! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:
• offer you our services and features;
• contact you with information about the E-zevis App (e.g., updates and new features);
• personalize the E-zevis App/Sites and the content we deliver to you;
• conduct research and analytics about how you use and interact with the E-zevis App/Sites;
• resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
• investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
• to send you information about the promotions and offers we have available - if you’ve signed up for our communications or otherwise told us it’s OK (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
• protect our Users and third parties from harm.
Moderation Practices
We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded onto user profiles and items you listed) and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been violated, the relevant account will be subject to a warning and the user’s access restricted and/or blocked. Affected Users can contact E-zevis to contest the decision.
If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate or restrict access to your Account.
MORE INFORMATION ABOUT DISCLOSURES
Service Providers
We engage certain trusted third parties to perform functions and provide services to us (“Service Providers”). The suppliers with which E-zevis shares User personal data vary depending on a variety of factors, such as which of our E-zevis App, E-zevis Sites and E-zevis services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:
• Billing services – to allow customers to purchase paid features of E-zevis App (for example, Google Play);
• Authentication services – to allow customers to authenticate their account (for example, passbase);
• Social media providers – to allow customers to create/connect their E-zevis account with their account(s) on such platforms (for example Facebook, Google or Apple);
• Product improvement and market research – we use various third party platforms (such as Qualtrics or Survey monkey) to carry out customer surveys and market research to improve our products and services;
• IT services – some of the third-party software providers used in the operation of our business may process Users’ personal data (for example, if a User contacts us via social media with a support inquiry, their inquiry is processed by our software provider Retrocube).
We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary to the service they are providing. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.
Marketing Services Providers
We partner with providers of marketing services (such as Google for example) (‘Marketing Services Providers’) to help us market and advertise our App and services on third party websites and applications and measure the effectiveness of our advertising campaigns. For example:
• to exclude you from advertising campaigns aimed at finding new users, if you already have a E-zevis account;
• to show E-zevis adverts to users who have visited the E-zevis App/Sites but haven’t yet created a E-zevis account;
• to create an audience for our advertisements of other potential users who have similar characteristics to you based on the information the Marketing Service Providers holds about you (also known as a Lookalike Audience); or
• to include you in a ‘custom audience’ that will receive E-zevis advertising content (a custom audience is essentially a list of people who we think are most likely to be interested in a particular advertisement).
We share a limited amount of your personal data with these Marketing Services Providers, such as:
• the advertising identifier associated with your device (this is a random number assigned by your mobile device manufacturer (for example Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked in an app, and when an ad causes a ‘conversion’ (for example, downloading the app advertised to you))
• your estimated location (based on your IP address)
• age
• data about your visit to E-zevis websites or E-zevis App and action taken on those (for example if you downloaded E-zevis App or created an account with E-zevis App)
• a hashed* version of your email address (to create ‘custom audiences’).
*Hashing is a way of encrypting information by turning it into a combination of random numbers and letters - this code cannot be traced back to the email address. When hashed email addresses are sent to a Marketing Service Provider, they’re then matched against the Provider’s own existing list of their own users’ hashed information and our ads are served to those of our users who have successfully been matched with the Provider’s. Matched and unmatched hashes are then deleted by the Provider.
For more information about how we use cookies and other tracking technologies, including how you can set and manage your preferences with regards to such technologies, please see our Cookie Policy.
In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.
Where we share data with Facebook as our Marketing Service Provider (including via the Facebook “Like” function), we are Joint Data Controllers with Facebook USA for this processing. This arrangement means that E-zevis has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information as independent data controller can be found in Facebook USA’s Data Policy. If you want more information relating to the nature of the arrangement we have in place with Facebook, please email
data@ezevis.com.
This data referred to above can include actions that you take on our website such as your interactions with our Sites or other information collected from cookies or similar technologies including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook).
4. WHAT OTHERS MAY SEE ABOUT YOU.
We think our Users and items listed are amazing, and we want you to share how amazing your items are, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them.
When using the E-zevis App, you should assume that anything you post or submit on the E-zevis App may be publicly-viewable and accessible, both by Users and non-users of the E-zevis App. We want our Users to be careful about posting information that may eventually be made public.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. Please remember that photographs that you post on E-zevis may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of this information and making it public to other Users.
Your E-zevis profile and other information you make available via the E-zevis App, including certain information added to your profile through third party accounts (such as Facebook, Apple or google – see section 7 of this Privacy Policy for more information about this) may be viewed and shared by Users with individuals who may or may not be users of the E-zevis App. For example, a User may recommend your item to his or her social media friend(s) by taking a screenshot of your item and sharing it, regardless of whether such friend(s) is also a User of the E-zevis App.
Please also note that in certain countries (currently, South Korea only), Users are provided with functionality enabling them to download a copy of their conversation history (as this is required by local laws) and that E-zevis has no control over how users may then publish or use that information.
If you log in to or access the E-zevis App through your Facebook account or another third-party account on a device which you share with others, remember to log out of the E-zevis App and the relevant third-party account when you leave the device in order to prevent other users from accessing your Bumble account.
5. OUR POLICY TOWARDS AGE.
Although we want as many people as possible to enjoy our innovation, you have to be at least 18 years old to use the E-zevis App - sorry kids, we know E-zevis is cool, but you’ll have to come back when you’re old enough!
E-zevis does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.
6. SECURITY.
At E-zevis, we pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information.
Unfortunately, no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:
1. Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
2. Please don’t share the password you use to access your E-zevis Account with anyone else!
3. Change your password periodically.
If you ever think someone has had access to your password or Account, please email us immediately on
alert@ezevis.com.
We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.
7. LINKING OTHER ACCOUNTS TO E-ZEVIS.
Using your social media details to sign in to E-zevis App
When you sign in to E-zevis App using your Facebook, Google or Apple accounts, you give permission to these third party apps to share with us your personal details including your profile picture. Unless you opt-out, you also give permission to third party apps to share with us your email address, date of birth, profile photos, phone number, gender, Page likes and current town/city.
If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, a name (that can be edited by you) and an email.
If you remove the E-zevis app from your third party apps, we will no longer have access to this data. However, we will still have the personal data that we received when you first set up your E-zevis account using your third party apps (you must delete your E-zevis account entirely for us to no longer have access to this data).
8. YOUR CALIFORNIA PRIVACY RIGHTS.
For Users who are California residents, you have the following rights (in addition to those listed at section 10 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:
1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at
data@ezevis.com.
From time to time, as part of a joint promotion with a third party, we may, if you participate in such promotion, disclose your contact information to the third party to allow them to market their products or services to you. Where this is a condition for participation in a promotion, we will always let you know before when you enter the promotion. Please follow the instructions provided to you by third parties to unsubscribe from their messages.
In addition, under California law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the E-zevis App.
9. YOUR RIGHTS.
Privacy laws applicable in your country may give you the following rights:
1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.
The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.
If you want to exercise any of your rights listed above please email our Data Protection Team at
You can also contact us by mail at the following address:
1455 NW Leary Way,
Suite 400,
Seattle, WA, 98107-5138, USA.
For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.
If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above. If you feel we have not resolved your concern, you have the right to make a complaint with your local privacy or data protection regulator. Alternatively, if you feel as though we are not abiding by the terms, you may also complain to the FTC: https://reportfraud.ftc.gov/#/.
10. DATA LOCATIONS.
We want you to be able to access E-zevis wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, UK, EU, Africa, Australia, and Asia. The hardware is located in third-party data centers not owned by the E-zevis. Data collected by Advertising Partners and other Service Providers may also be held outside the UK and the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses, and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place, please email data@ezevis.com.
11. DATA RETENTION AND DELETION.
We keep your personal information only as long as we need it for the legal basis relied upon (as set out in Section 2 above) and as permitted by applicable law. Please see “Profile Verification Information (Including Biometric Information)” in Section 1, above, to learn about our retention policy with respect to biometric information.
When you delete your Account, or it is deactivated by us, we make sure it is no longer viewable in the E-zevis App. For up to 30 days, it is still possible to restore your Account if it was accidentally deleted or wrongfully deactivated. After 30 days, we begin the process of deleting your personal information from our systems, unless:
1. we must keep it to comply with applicable law;
2. we must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behavior that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).
WARNING: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.
12. CHANGES TO THIS POLICY.
As E-zevis evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at ezevis.com/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within E-zevis.