Privacy policy

When you use our services, you are trusting us with your information. In our capacity as a data controller, we are responsible for collecting, processing and protecting your personal data in relation to our services and we commit to do so complying with the legal provisions in force.

About this privacy policy

This privacy policy explains what personal information we collect throughout our services, why and how we collect and process it, what do we do with it, how do we protect it and what are our and your rights and responsibilities in relation to privacy practices. It also details the tools at your disposal to update, manage, export, and delete your information.

By accepting our privacy policy, you are confirming that you have read and understood it. If you do not want us to collect or process your personal information in the ways described in this policy, you should not use our services.

As our business evolves, we reserve the right to change or update this privacy policy at any time. If we make a material change, we will provide you with reasonable notice prior to the change taking effect either by posting the revised privacy policy through the services and updating the last updated date or by emailing the email address associated with your account. Any material revisions to this privacy policy will become effective on the date set forth in our notice, and all other changes will become effective on the date we publish the change. You are responsible for reviewing and becoming familiar with any changes. If you access or use our services after the effective date of any changes, that use will constitute your acceptance of the revised privacy policy.

You will be subject to the privacy policy in force at the time that you use our services and by using our services, you are agreeing that we can process your information in the ways set out below.

Why do we collect data?

We need to collect, store and process your personal information for several reasons:

  • Perform the contractual obligations in our terms and conditions
  • Provide, troubleshoot, analyse and improve our services
  • Personalize your experience
  • Payments processing
  • Buying and selling process related information exchange
  • Recommendations of features, products and services
  • Communicate with you in relation to our services
  • Keep our services safe and secure
  • Detect, investigate, prevent, or take action regarding illegal activities, suspected fraud, abuse, threats to our property, or violations of our terms and conditions
  • Combat money laundering and terrorist financing
  • Comply with legal and regulatory obligations
  • Respond to official requests from a duly authorized public or judicial authority, including to meet legitimate national security or law enforcement requirements
  • Defend your, our or a third party’s legitimate and vital interests, such as those of users, sellers, or partners, including prevention of imminent physical harm or financial loss
  • Protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt
  • Purposes for which we seek your consent. Where none of the above reasons apply, we may also ask for your consent to process your personal information for a specific purpose that we communicate to you. Your consent is thus voluntary and you may withdraw it at any time.

How do we collect data?

In the course of providing our services, we collect or receive your personal information electronically, in a few different ways. For instance, you provide information to us, when you:

  • Accept our use of cookies
  • Subscribe to a newsletter
  • Search for products or services
  • Place an order through our services
  • Register an account
  • Provide information in your account
  • Offer your products on or through our services
  • Communicate with us or message us by phone, e-mail, or otherwise
  • Compile wish lists
  • Submit product and shopping experience related reviews

More about communication and messaging

On occasion, we may need to contact you. Primarily, these messages are delivered by email and therefore every account is required to keep a valid email address on file to receive them. We may also contact you by telephone to provide user support or for transaction-related purposes if you request that we call you.

Some messages from Zwoice are service-related and necessary for users and guest checkout users. You agree that we can send you non-marketing emails or messages, such as those related to our terms and conditions or policy updates, transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation, welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying conversations with buyers, and correspondence with our support team.

When you subscribe to a newsletter you agree to receive marketing communications from us. You may unsubscribe from these at any time by reaching out to us through our contact form, selecting “Other” in the drop down menu.

What data do we collect?

As a result of those actions, you might supply us with the information detailed below.

You may not be asked to provide us with all the below listed information, but we might require some of it, depending on which services you decide to use. You may choose not to provide certain information, but as a consequence you might not be able to take advantage of some of our services.

Information you give us

  • Name
  • Date of birth
  • Gender
  • Password
  • Email address
  • Phone number
  • Delivery and billing address
  • Shop name
  • Corporate, tax and financial information
  • People to whom purchases have been dispatched
  • Billing and payment information
  • Information and documents regarding identity and standing

Information you create

  • Shop description
  • Shop banner
  • Shop logo
  • Photograph
  • Image
  • Rating
  • Review
  • Email

We may contact individual shop owners confidentially to request more information about their shops or items listed through the services, or to ensure compliance with our rules and applicable law.

Automated information

When you use our services, we automatically receive, store and process information from your browser or device when you visit the website.

  • The Internet protocol (IP) address
  • Technical data
  • Cookie technologies
  • Usage
  • Pages you visit

More about cookie technologies

A cookie is a small piece of data that a website asks your browser to store on your device. The cookie allows the website to remember your actions or preferences over time.

Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.

If you disable all cookies on your browser, neither third parties nor we will transfer cookies to your browser. However, if you if you block or otherwise reject our cookies, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.

Cookie technologies we use include session and persistent cookies, UTM codes, local storage objects and out of approved third party cookies only Google analytics, with an anonymized IP address. We use them to help us function and understand how you use the services, in order to:

  • Maintain the security, safety and integrity of the services and recognise you when you sign-in to use our services;
  • Remember your custom preferences and keep track of items stored in your shopping cart;
  • Login in with the social network;
  • Conduct analytics to learn more about your interests, improve content, products, and performance of our services.

By choosing to use our services you agree to our use of cookies.

Analytics information

We retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for website safety and security, to improve website functionality, or we are legally obligated to retain them for longer time periods.

  • Purchase and content use history
  • The full Uniform Resource Locator (URL) clickstream to, through and from our website, including date and time
  • Products and/or content you viewed or searched for
  • Page response times
  • Length of visits to certain pages

Information from third parties

You may choose to register a Zwoice account using an external third-party application or service, such as facebook, google or twitter. You can also choose to share some of your activity on Zwoice on certain social media networks, which are connected to your Zwoice account. These choices are optional and we may receive information from those connected third-party applications.

  • Websites and social network pages containing information you made public
  • Information from our service providers or fraud prevention agencies

Please note that this policy does not apply to the practices of third parties that we do not own or control or individuals that Zwoice does not employ or manage. Hence, if you provide your information to others, different practices may apply to the use or disclosure of the information that you provide to them.

For the purposes of European law, our sellers are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the services. We are not responsible for the privacy or security practices of any third parties, including sellers. We thus encourage you to read their privacy policies and ask questions before you disclose your personal information to them.

Sharing, disclosure and transfer

This section details our privacy practices regarding information sharing, disclosure and transfer.

Sharing and disclosure

We will not share or disclose your personal information to third parties without your consent, except as specified in this policy.

With whom may we share your data?

  • Our employees
  • Our service providers
  • Our sellers
  • The financial and judicial authorities, arbitrators and mediators, public agencies and state agencies, upon request and to the extent permitted by law

Transfer

We will transfer personal information only to the countries to which we are permitted by law to transfer it, and we will take steps to ensure that your personal information continues to enjoy appropriate protections. By using the services, you acknowledge that Zwoice will use your information in any country where we operate.

However, please note that when your information is moved from your home country to another country, the laws, standards and rules that protect your personal information, including the access rights of authorities, in the country to which your information is transferred may be different from those in the country in which you live.

If you are aware of any event or incident by which data would have been transferred or disclosed to someone non-authorised, you should inform us immediately by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu.

Security

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received.

Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the services.

On our side, we encrypt certain information using secure socket layer technology (SSL).

Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Retention

We and our sellers will retain your information only for as long as is necessary to fulfill the purposes set out in this policy, as long as your account is active, as required by law, or as needed to provide the services to you. We will do so to the extent necessary to comply with legal obligations, resolve disputes, enforce agreements, and as otherwise described in this policy.

If you no longer want us to use your information to provide the services to you, you may close your account by contacting us. However, please note that closing your account may not free up your email address, username, or shop name (if any) for reuse on a new account.

Your rights

You have rights with respect to your information that we process, and you may:

  • Right of access, access your personal data and/or obtain a copy of it anytime through the “Privacy” section of your Zwoice account.
  • Right of rectification, change, and update or correct your personal data, and contact preferences through the “Profile”, “Address” and, if applicable, “Shop” sections of your Zwoice account.
  • Right of erasure, remove optional information that you no longer wish to be publicly visible by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu. Right to restrict, restrict or limit the ways in which we use your personal information, such as control the receipt of marketing communications from Zwoice by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu.
  • Right to withdraw your consent, withdraw your consent to our processing of your information by contacting us by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu. In such cases, we will cease processing your information and delete it, except for information that we are required to retain, unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. This deletion is permanent and your account cannot be reinstated.
  • Right to object, choose to remove permission for an external third party application, such as facebook, by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu.
  • Right of data portability, in certain circumstances, you have the right to take back personal data that you have supplied to us, or, where this is technically possible, to request that the data be transferred to another data controller by reaching out to us through our contact form, selecting “Privacy, disputes & legal” in the drop down menu.
  • Right to complain, in accordance with the applicable regulations, you may also file a complaint with our principal supervisory authority, the Commission Nationale pour la Protection des Données (CNPD) in Luxembourg, www.cnpd.lu, or with any other competent authority. If you live in the EEA, you may also file a complaint with your local data protection regulator.

We will honour all requests at our earliest convenience and within the limits and conditions set out under applicable data protection rules.

Your responsabilities

Please note that our terms and conditions require all users to be at least 18 years of age. You are responsible for any and all account activity conducted by a minor on your account.

Each user commits to provide exact, accurate, complete and updated information about themselves, and keep it updated at all times. It is not allowed to use false information or impersonate another person or company through your account. Each user is solely responsible for consequences of providing incorrect, misleading or outdated information both to Zwoice or another user. You are thus responsible for ensuring that the details you provide us with are correct and complete, and for informing us of any changes to the information you have provided.

If you sell using our services, you may also need to process personal information, such as buyer name, email address, or shipping address, and, to the extent you do so, under EU law, you are an independent controller of data relating to other users that you may have obtained through the services. We expect you to respect the privacy of the user whose information you have received.

You are thus responsible for protecting the user information you receive or process and complying with all relevant legal requirements, as well as data protection and privacy laws when you use the services. Such laws may require that you post, and comply with, your own privacy policy, which must be accessible to Zwoice users you interact with and compatible with this policy and our terms and conditions. Please find a template here.

As a data controller, to the extent that you process user personal information outside of the services, you may be required under applicable data protection and privacy laws to honor requests for data access, portability, correction, deletion, and objections to processing.

Also, if you disclose personal information without the buyer’s proper consent, you are responsible for that unauthorized disclosure. This includes all disclosures you make, as well as unintentional data breaches. For example, you may receive a buyer’s email address or other information as a result of entering into a transaction with that buyer. This information may only be used for Zwoice-related communications or for Zwoice-facilitated transactions. You may not use this information for unsolicited commercial messages or unauthorized transactions. Please bear in mind that you are responsible for knowing the standard of consent required in any given instance.

If Zwoice and you are found to be joint data controllers of personal information, and if Zwoice is sued, fined, or otherwise incurs expenses because of something that you did as a joint data controller of buyer personal information, you agree to indemnify us for the expenses we occur in connection with your processing of buyer personal information.

Contact

If you have any privacy related questions or concerns, or wish to contact our data protection officer please reach out to us through our contact form and select “Privacy, disputes & legal” in the drop down menu. Please remember to include a scanned copy of your ID as proof of identity.

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