Short version: Your privacy is very important to EasyWeb s.r.o. Therefore, we will use your complete data only for the operation and optimization of our product. We will never give your sensitive data such as name, profile picture or e-mail address to third parties for advertising purposes.
If you would like to take precautions against the use of data for advertising purposes, you can deactivate personalized advertising in the app settings under privacy and in your device settings. On an Apple device, you can do this in the iOS settings under "privacy" -- "advertising" by activating the option "no ad-tracking" or on a device with android system under "Google settings" (or "Settings" and therein "Google"), then click on "show" and click on the button at "deactivate interest-based display". You can always delete the IDFA or the advertising ID in the device settings ("reset Ad-Id"). In this case a new identification number will be created, which will not be merged with the previously collected data. On a Huawei device, you have to do the following: Swipe up on the home screen, tap the gear icon, and turn off the "Magazine unlock" feature. If you do not want to disable the option, you can easily check your subscription in "Magazine unlock". You should check the "Travel" and "Transportation" sections to see if they are checked or unchecked. If you find them there, you should simply uncheck them.
The long version:
EasyWeb s.r.o., Husovo Namesti 1, 267 12 Lodenice, Czech Republic (hereinafter "EasyWeb s.r.o." or "we/us") operates the mobile app Zeniors (hereinafter: "Zeniors App" or "Zeniors"), which is available for download for various operating systems, a platform for chatting, getting to know and meeting other people and is the responsible entity.
The service offered is a freemium model, whereby the user of Zeniors (hereinafter: "user" or "you") can create a profile (hereinafter: "user profile") free of charge via the Zeniors app, upload pictures and exchange information with other users and their user profiles if interested. The user has the opportunity to take advantage of the functions of a free membership of Zeniors. Zeniors also offers a paid premium service (VIP membership), which enables the user to access additional, exclusive functions.
Your data will be collected, processed and used according to the currently valid national and EU legal requirements.
EasyWeb s.r.o. does not require a clear name. The user can also enter a pseudonym instead of a name. For individual parts of Zeniors - for example, if you receive money from us - it may be necessary for tax reasons to provide us with your name, address and nationality. In such cases we will inform you separately.
1. How is my data collected, processed and used when downloading the Zeniors app?
1.1. Download the Zeniors App
When you download the Zeniors app, the necessary information is transferred to the respective app store operator. Depending on the App Store, this information may include, for example, the e-mail address or customer number of the App Store user of the respective App Store, the time of the download and an individual device ID number. However, EasyWeb s.r.o. has no influence on this data collection and is not responsible for its processing. The corresponding data protection declarations/ settings of the respective App Store operator apply.
EasyWeb s.r.o. processes the data provided by the respective app store operator to the extent necessary for downloading the Zeniors app to the end device.
1.2. Installation and permissions
EasyWeb s.r.o. requires various access options and information for the technical functioning of the Zeniors app and for providing the services offered with the Zeniors app.
Depending on the operating system, permission to access individual functions and information is requested during the installation process. The access permissions include location, notifications and mobile data.
These authorizations can be partially withdrawn manually in the settings of the end device. However, it must be taken into account that the Zeniors app can only be used to a limited extent or not at all without the corresponding approvals. Depending on the app version, permissions are queried before or after installation.
2. How is my data collected, processed and used when I visit the Zeniors app without creating a user profile at Zeniors?
When installing the Zeniors app without creating a user profile, EasyWeb s.r.o. collects the following data transmitted by the user's terminal device:
- Push Handle (for sending push messages)
- Location data (GPS Location), if the user has given the app permission in his device
- Country code
- Device data, such as manufacturer, device type, advertising ID, operating system and version.
Such data is required for the installation of the Zeniors app as such or is used for statistical purposes, to optimize Zenior. The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Zeniors platform. For this purpose, we store the collected data in complete form for up to 90 days.
Location data is collected, processed and used to enable the user to use the so-called Location Based Service, which offers suggestions tailored to the respective location from the moment of registration. For more details on location data, please also see paragraph 3.1.3.
3. How is my data collected, processed and used after creating a user profile and when using the Zeniors app?
3.1. Data that you have provided us with
3.1.1. Mandatory information
When creating the user profile and registration, the following information must be provided. Note: When registering with Facebook Login, Google Login, Apple Login, the required data is partially transferred automatically.
- E-mail address
- User name (pseudonym)
- Date of birth
The data provided will be collected, processed and used for the purpose of using Zeniors. Among other things, the information is used for addressing, authentication, age verification, personalization of the profile, display of other suitable user profiles and in pseudonymous form for advertising purposes (see also paragraph 4).
We delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR.
3.1.2. Voluntary information
The user can make a variety of voluntary entries in his user profile and set search filters. This serves in particular the function of Zeniors to select recommendations for other user profiles according to different criteria for the user and to display them within Zeniors. Additional information increases the probability of coming into contact with suitable user profiles. This information is voluntary for the user and can be viewed, entered, changed or deleted in the profile under Details.
The data provided will be collected, processed and used by us for the purpose of using Zeniors. This voluntary information is visible to other logged-in users within Zeniors as "public", but can be deleted or changed by the user profile owner at any time under the settings within the user profile. Furthermore, this data can also be processed and used for advertising purposes (see details on advertising under paragraph 4).
We delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR.8
3.1.3 Location data
The range of services offered by Zeniors also includes so-called location-based services, which present the user with special offers tailored to the respective location. This enables the user to be shown other users, in particular those who are in the vicinity. To provide these functions within the Zeniors app, Zeniors collects location data using GPS of the terminal device used, as well as location data from nearby radio access nodes.
The user can adjust this function in the settings of the operating system on his terminal device at any time, i.e. allow the collection of location data or revoke its use.
The location data is also processed by Zeniors for advertising purposes, unless the user has objected to its use in the app settings. (see details on advertising under paragraph 4).
We store location data in unabridged form for up to 14 days and in abridged form for up to 90 days.
The legal basis for this processing of personal data is Art. 6 I lit. b) or f ) EU-GDPR.
3.2 Data we receive as a result of your use of the Zeniors app
3.2.1 IP addresses and network data
The IP addresses and related network data (e.g. the country in which the IP is registered) of users are recorded for security and verification purposes. The purpose is to prevent misuse of the service.
The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Zeniors platform.
To this end, we store the collected data in full for up to 90 days, after that until your profile is deleted. The legal basis for this processing of personal data is Art. 6 I f) EU-GDPR.
3.2.2 Device data
When using the app or the website, we receive information about the device used, such as the manufacturer, operating system, advertising ID.
The data is processed and used to prevent and combat fake profiles, illegal acts and spam, and to ensure the integrity and stability of the Zeniors platform.
To this end, we store the collected data in complete form for up to 90 days and delete this data when you delete your user account. The legal basis for this processing of personal data is Art. 6 I f) EU-GDPR.
3.2.3. Event data
By using the app, we receive information about your actions (a so-called event) in the app, for example when you click data, search for users, create a match or send messages.
The data provided will be stored, processed and used by us for the purpose of using Zeniors. This serves in particular the function of Zeniors to select recommendations for other user profiles according to different criteria for the user and display them within Zeniors. This additional information increases the probability of coming into contact with suitable user profiles. This data is an important part of understanding which profiles are likely to be of interest to you and which profiles you want us to display.
This data is also stored, processed and used to prevent and combat fake profiles, illegal activities and spam and to ensure the integrity and stability of the Zeniors platform.
We delete this data when you delete your user account.
The legal basis for this processing of personal data is Art. 6 I lit. b) EU-GDPR or Art. 6 I lit. f) EU-GDPR.
3.3 Payment details (In-App purchases)
We do not collect or process your personal information when you purchase or download Zeniors through an App Store. Such data, especially data for electronic payment processing, is only collected and processed directly by the App Store concerned. When using the App Stores, please refer to their privacy policies:
- Apple App Store: www.apple.com/uk/privacy/
- Google Play Store: policies.google.com/privacy
- HUAWEI AppGallery: consumer.huawei.com/en/privacy/privacy-policy/
If you have any questions regarding the processing of your personal data by the App Store concerned (e.g. How can I delete my data?), please contact the App Store where you downloaded or purchased an App directly.
4. How will my data be used by Zeniors for advertising purposes?
We use data for advertising purposes in two ways:
- For self-promotion
- To display personalized advertising
4.1. How will Zeniors use my data for self-promotion?
On our platform, we display self-advertising to our users and also inform them by e-mail, e.g. about one-off promotions, reduced package prices or similar offers. To be able to display suitable offers, we use information that is provided to us by the user (such as profile data) and information that we automatically receive as a result of using our platform.
At any time, the user can object to the use of the service for advertising purposes by deactivating personalized advertising in the app settings under Privacy, or in his device settings.
The data will only be passed on as described under paragraph 6.
The legal basis for this processing is the legitimate interest of Zeniors according to Art. 6 I lit. f GDPR.
4.2. How will Zeniors use my information to display personalized advertising?
4.2.1. Personalized advertising
EasyWeb s.r.o. has chosen a freemium model for Zeniors, i.e. a basic version of Zeniors can be used by any user without paying a fee. However, the user is shown advertising in the free version. The advertising displayed on Zeniors includes its own advertising content (e.g. via Zeniors' VIP membership).
4.2.2. Sharing of data with third parties
EasyWeb s.r.o. only shares data with third parties in exceptional cases when this is urgently necessary for the function of Zeniors. Otherwise, no data will be shared with other third parties.
4.2.3. Legal basis for the use of data to display personalized advertising
EasyWeb s.r.o. bases the processing and disclosure of the above data on the fulfillment of the contract with the user, his or her consent and the legitimate interest of Zeniors.
EasyWeb s.r.o. provides its service in the Freemium model, which means that parts of Zeniors are free of charge. To enable users to use the Zeniors platform free of charge, Zeniors displays advertising and uses personal data for this purpose in accordance with the above-mentioned provisions.
A prerequisite for the transfer of the above data to the recipients is always that contractual, legal, technical and organizational measures are taken to ensure that the data is used exclusively in a manner that complies with data protection laws.
By using the app, the user agrees to the transfer of his data, which is necessary in exceptional cases, already in the free version.
EasyWeb s.r.o. has limited its selection of data to those data that, even if they become known, whether through breach of law or hacking attacks on EasyWeb s.r.o. partners, do not have a high level of sensitivity for individual users. For this reason, Zeniors only passes on the data in a pseudonymized form, i.e. individual users can only be identified with a great deal of technical effort and by breaking the law.
Zeniors only passes on data that the user has voluntarily made public in the Zeniors app and that is therefore recognizable by the user as being of low sensitivity, and device and connection data that by its very nature is not sensitive.
5. Which cookies and other services are integrated?
The Zeniors app was developed technologically in a way that it does not require cookies and therefore does not store cookies.
EasyWeb s.r.o. offers the user the possibility to sign up for Zeniors with Facebook Connect. To register, the user is redirected to the Facebook page (operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA), where he/she logs in with his/her user data, if not already logged in. By clicking the user's name, the respective Facebook profile and the user profile at Zeniors are then linked together. Through the link, EasyWeb s.r.o. automatically receives the user's data from Facebook in the form of the e-mail address and other data within the user's public Facebook profile. The public Facebook profile contains data that the user has made available to the public on Facebook. Typically, the public Facebook profile includes the following data: Name, profile picture, gender, language, country, age range, Facebook ID, friends, likes and relationship status.
The legal basis for data processing is then the consent of the user according to Art. 6 I lit. a) GDPR.
5.3 Google Ads (formerly Google AdWords)
We use "Google Ads" (formerly Google AdWords), a service of Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Ads enables us to draw attention to our attractive offers by means of advertising on external websites. This enables us to determine how successful individual advertising measures are. These advertising materials are delivered by Google via so-called "AdServers". We use so-called AdServer-Cookies for this purpose, through which certain parameters for measuring success, such as the display of the ads or clicks by users, can be measured. If you reach Zeniors via a Google ad, Google Ads will store a cookie on your device. These cookies usually expire after 30 days. They are not intended to identify you personally. The following information is usually stored as analysis values for this cookie: Unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies enable Google to recognize your web browser. If a user visits certain pages of an ads client and the cookie stored on their computer has not expired, Google and the client can recognize that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each ad client. Cookies cannot be tracked through the websites of ad clients. We ourselves do not collect and process any personal data in the advertising measures mentioned above. We only receive statistical evaluations from Google. By means of these evaluations we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material, in particular we cannot identify the users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. To our knowledge, Google receives the information that you have called up the corresponding part of Zeniors or clicked on an ad from us. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, there is a possibility that Google will find out and save your IP address.
We use Google Ads for marketing and optimization purposes, in particular to deliver ads that are relevant and interesting to you, to improve campaign performance reports and to achieve fair calculation of advertising costs. This is also our legitimate interest in the processing of the above data by the third party provider. You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in your web browser settings. Please note that in this case you may not be able to use all functions of Zeniors to their full extent. You can also prevent the storage of cookies by setting your web browser to block cookies from the domain "www.googleadservices.com" (www.google.com/settings/ads). We would like to point out that this setting will be deleted if you delete your cookies. In addition, you can deactivate interest-based ads by clicking on the link http://optout.aboutads.info. Please note that this setting will also be deleted if you delete your cookies.
Third party information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Irland
Further information on the use of data by Google, on setting and objection possibilities as well as on data protection can be found on the following websites of Google:
6. How data is disclosed or passed on
EasyWeb s.r.o. does not pass on users' personal data to third parties unless the user has given his or her consent to do so, the transfer is required by law or is permitted by law.
6.1 General information on the disclosure of personal data
User data and other data
EasyWeb s.r.o. may pass on customer data to the following third parties for the purpose of executing the contract:
- External service providers and agents. EasyWeb s.r.o. may engage external companies or individuals to process customer data. The legal basis for the transfer is Art. 28 GDPR.
- Affiliated companies for order processing. EasyWeb s.r.o. may commission affiliated companies to process customer data. The legal basis for the transfer is Art. 28 GDPR.
- Affiliated companies as the responsible body. EasyWeb s.r.o. may pass on customer data within the group of companies for internal administrative purposes. The legal basis for the transfer is Art. 6 I lit.f GDPR in conjunction with Recital 48 GDPR.
EasyWeb s.r.o. may share or disclose customer information as follows:
- In the context of changes in the business structure. In connection with mergers, acquisitions, insolvency proceedings, dissolution, restructuring, sale of some or all of the assets of Zeniors, financing, acquisition of some or all of our business, similar transactions or proceedings or steps contemplating such activities (e.g. due diligence).
- To the extent permitted by law. To comply with any legal or regulatory requirement, and in response to lawful requests, court orders or legal proceedings.
- To enforce the rights of EasyWeb s.r.o., to prevent fraud and to ensure security. To protect and defend the rights, property or safety of Zeniors or third parties, including the enforcement of contracts and policies, and in connection with investigating and preventing fraud.
- EasyWeb s.r.o. may use data aggregated or adjusted for personal characteristics for any purpose. For example, EasyWeb s.r.o. may share aggregated or personally identifiable information with partners or others for business or analytical purposes, such as publishing how many messages Zeniors will send in a day.
- EasyWeb s.r.o. passes on customer data in pseudonymized form to advertising partners in accordance with paragraph 4.
- EasyWeb s.r.o. passes on pseudonymized data to analysis and tracking services in accordance with paragraph (5.2).
6.2 Categories of data recipients
EasyWeb s.r.o. will only disclose your personal data to third parties if this is necessary to fulfill our own business purposes (i.e. in particular to provide the services we owe you), if you have given your consent to do so, if it is in our legitimate interest to do so, or if we are required to do so by law or by court or governmental order.
We cooperate with external service providers within the scope of data processing. This is usually done on the basis of so-called contract processing; in which we remain responsible for data processing. We check each of these service providers in advance for the measures they have taken for data protection and data security and thus ensure that the contractual regulations for the protection of personal data provided for by law are observed.
The following categories of recipients currently receive personal information from us:
- State agencies and courts
- Hosting service provider
- E-mail dispatch service provider
- E-mail marketing service provider
- Services to provide customer support
- Affiliated companies
Depending on the nature of the services provided, EasyWeb s.r.o. may also use affiliates as data processors to provide some or all of the services offered to the customer.
6.3 Third Countries
Data transmissions to third countries take place, but only in compliance with the legal requirements for admissibility. Data transmissions to the following countries are carried out in compliance with the respective legal admissibility requirements:
- USA (EU-US Privacy Shield Agreement or EU standard contractual clauses)
- Israel (Adequate level of data protection recognized by EU Commission)
- India (EU standard contract clauses)
The Privacy Shield Agreement, the Adequacy Decision and the EU standard contractual clauses can be viewed on the website of the EU Commission (ec.europa.eu/info/law/law-topic/data-protection_en).
7. How is data processed and used to prevent and combat fake profiles, illegal activities and spam, and to ensure the integrity and stability of the Zeniors app?
To combat fake profiles, illegal activities (fraud, extortion, prostitution, etc.), SPAM (third-party advertising) and to ensure the integrity and stability of the Zeniors platform, personal data is used as follows:
- IP and email addresses are stored to detect spam and illegal activities as long as the user is active.
- Messages are automatically checked for keywords, but are not stored for this purpose.
- Personal data such as gender, age and location are stored for active users and are used in combination with other, non-personal data to identify anomalies.
- To verify suspicious profiles via SMS, telephone numbers already used are stored, but cannot be linked to the verified user.
Zeniors supports the aforementioned data processing on the basis of art. 6 I lit. f GDPR. Zeniors has a legitimate interest in keeping its platform stable and free of SPAM, legal infringements and fake profiles.
8. How does the data deletion and backup process work?
When the user profile is deleted (note: not by deleting the Zeniors App!) or when we are notified accordingly, all collected data of the user is deleted or made anonymous. In addition, the user can at any time delete individual data in the profile himself or request us to do so via a corresponding notification.
Excluded from the deletion are data that must be kept due to legal regulations, for the execution of contracts or for the fulfillment of contracts with other users. Therefore, in the event of a deletion, Zeniors does not delete the following data in particular immediately, but only after the expiry of a period of time:
- Payment data and premium redemption data that we have to store for tax reasons. (After expiry of the statutory retention periods)
- Data that you have shared with other users in chats, such as messages or pictures (see below.)
When do we delete data that a user has shared with other users?
We delete data that is publicly accessible in user profiles, e.g. profile pictures, pictures in the stream and the profile data as soon as immediately according to the above standards.
We cannot simply delete information that a user has non-publicly shared with other users on the Zeniors app without violating the rights of other users. Therefore, chat content is only deleted after both users have deleted each other.
When does the deletion take place?
Deletion from the production databases and thus from the Zeniors interface is immediate; however, it can take up to 14 days before deletion from all server layers, cache memories and backup databases of Zeniors occurs.
If deletion is not possible, the data will be made anonymous or blocked.
EasyWeb s.r.o. reserves the right to check profile files before deleting them and, if necessary, to save them if, based on certain facts, there is a suspicion that the user profiles are being used in a manner that violates the law or the contract. This serves to protect the users of the services of EasyWeb s.r.o.
Regardless of the deletion of data triggered by the user's profile deletion, Zeniors automatically deletes historical data that is no longer required for the fulfillment of the contract (e.g. historical location data and IP data) at regular intervals.
EasyWeb s.r.o. creates so-called backups to secure the data stocks, which are overwritten after 14 days and thus permanently deleted. If these backups contain log files, they are also deleted. If a user profile is completely deleted, the log files are also deleted.
9. What data security measures are in place at Zeniors?
EasyWeb s.r.o. takes user confidence and data protection extremely seriously. To prevent unauthorized access or disclosure of user data, to maintain data integrity, and to ensure the appropriate use of information, EasyWeb s.r.o. implements appropriate physical, technical, and administrative procedures to safeguard the information collected by EasyWeb s.r.o..
To ensure the best possible protection of the user's data, the Zeniors app uses a secure SSL connection, i.e. the data is transmitted in encrypted form between the servers and the browser as well as between the servers and the app.
10. User rights: Consent and revocation, information, correction, deletion, transfer
10.1 Consent and revocation
The user can revoke his consent at any time with effect for the future. This can be done by deleting the user profile (not the Zeniors App), at the specified locations in the Zeniors App within the user profile or by sending us an e-mail or letter:
Husovo Namesti 1,
267 12 Lodenice,
- E-MAIL: firstname.lastname@example.org
10.2 Information, correction, deletion, transmission
According to the applicable laws, the user has a right to free information about the personal data stored by him and, if applicable, a right to correction and/or deletion or transfer of this data.
For this purpose, the user can contact email@example.com by e-mail, for example.
The user also has the right to complain to a data protection supervisory authority about the processing of your personal data by the Zeniors App.
12. Contact person for data protection and data protection officer
In the event of questions regarding the collection, processing or use of personal data, the disclosure, correction, blocking or deletion of data as well as the revocation of consents granted, the user should - if applicable - delete his user profile (not the Zeniors App) or change it at the specified points in the Zeniors App within the user profile or contact us by e-mail or letter:
Husovo Namesti 1,
267 12 Lodenice,
- E-MAIL: firstname.lastname@example.org