Privacy Policy

this application collects some personal data from its users. users may be subject to different protection standards and broader standards may therefore apply to some. in order to learn more about the protection criteria, users can refer to the applicability section. we may revise this policy as well as update our services and the platform from time to time, so please keep visiting this page regularly to take notice of any changes we make. if you do not agree with any part of this policy, please stop using our services immediately.

owner and data controller

zywa technologies ltd difc, dubai, united arab emirates

owner contact email: care@zywa.co

types of data collected

among the types of personal data that this application collects, by itself or through third parties, there are: camera permission; precise location permission (continuous); biometric data access permission; photo library permission; tracker; usage data; unique device identifiers for advertising (google advertiser id or idfa, for example); device information; geography/region; number of users ; number of sessions; session duration; application opens; application updates; launches; operating systems; geographic position; first name; last name; gender; date of birth; phone number; physical address; email address; username; password; profession; country; zip/postal code; city; picture; prefix ; profile picture; budget; field of activity; house number; language; various types of data.

complete details on each type of personal data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the data collection. personal data may be freely provided by the user, or, in case of usage data, collected automatically when using this application. unless specified otherwise, all data requested by this application is mandatory and failure to provide this data may make it impossible for this application to provide its services. in cases where this application specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the service. users who are uncertain about which personal data is mandatory are welcome to contact the owner. any use of cookies – or of other tracking tools – by this application or by the owners of third-party services used by this application serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the cookie policy, if available. users are responsible for any third-party personal data obtained, published or shared through this application and confirm that they have the third party’s consent to provide the data to the owner.

mode and place of processing the data

methods of processing

the owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. the data processing is carried out using computers and/or it enabled tools, following organizational procedures and modes strictly related to the purposes indicated. in addition to the owner, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, it companies, communications agencies) appointed, if necessary, as data processors by the owner.

the updated list of these parties may be requested from the owner at any time.

place

the data is processed at the owner’s operating offices and in any other places where the parties involved in the processing are located. depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. to find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal data. if any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with the owner using the information provided in the contact section.

retention time

personal data shall be processed and stored for as long as required by the purpose they have been collected for.

therefore:

• personal data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.

• personal data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.

the owner may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn.

furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 once the retention period expires, personal data shall be deleted. therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

the purposes of processing

the data concerning the user is collected to allow the owner to provide its service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its users or third parties), detect any malicious or fraudulent activity, as well as the following: device permissions for personal data access, social features, analytics, beta testing, location-based interactions and registration and authentication provided directly by this application.

for specific information about the personal data used for each purpose, the user may refer to the section “detailed information on the processing of personal data”.

device permissions for personal data access

depending on the user’s specific device, this application may request certain permissions that allow it to access the user’s device data as described below.

by default, these permissions must be granted by the user before the respective information can be accessed. once the permission has been given, it can be revoked by the user at any time. in order to revoke these permissions, users may refer to the device settings or contact the owner for support at the contact details provided in the present document.
 the exact procedure for controlling app permissions may be dependent on the user’s device and software.

please note that the revoking of such permissions might impact the proper functioning of this application.

if user grants any of the permissions listed below, the respective personal data may be processed (i.e accessed to, modified or removed) by this application.

biometric data access permission

used for accessing the user’s biometrical data and/or authentication systems, such as for instance, faceid.

contact list permission
we allow users to discover their contacts on zywa’s platform. we require this permission to sync their contacts. syncing of contacts is an action that is optional, and is manually triggered by the user

camera permission

used for accessing the camera or capturing images and video from the device.

photo library permission

allows access to the user’s photo library.

precise location permission (continuous)

used for accessing the user’s precise device location. this application may collect, use, and share user location data in order to provide location-based services.

detailed information on the processing of personal data

personal data is collected for the following purposes and using the following services:

analytics

the services contained in this section enable the owner to monitor and analyze web traffic and can be used to keep track of user behavior.

google analytics for firebase (google llc)

google analytics for firebase or firebase analytics is an analytics service provided by google llc.
in order to understand google’s use of data, consult google’s partner policy.

firebase analytics may share data with other tools provided by firebase, such as crash reporting, authentication, remote config or notifications. the user may check this privacy policy to find a detailed explanation about the other tools used by the owner.

this application uses identifiers for mobile devices and technologies similar to cookies to run the firebase analytics service.

users may opt-out of certain firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other firebase related sections of this privacy policy, if available.

personal data processed: application opens; application updates; device information; geography/region; launches; number of sessions; number of users ; operating systems; session duration; tracker; unique device identifiers for advertising (google advertiser id or idfa, for example); usage data.

place of processing: united states – privacy policy.

beta testing

this type of service makes it possible to manage user access to this application, or parts of it, for the purpose of testing a certain feature or the entire application.
 the service provider may automatically collect data related to crashes and statistics related to the user’s use of this application in a personally identifiable form.

google play beta testing (google llc)

google play beta testing is a beta testing service provided by google llc.

personal data processed: usage data.

place of processing: united states – privacy policy.

testflight (apple inc.)

testflight is a beta testing service provided by apple inc.

personal data processed: device information; usage data.

place of processing: united states – privacy policy.

device permissions for personal data access

this application requests certain permissions from users that allow it to access the user’s device data as described below.

device permissions for personal data access (this application)

this application requests certain permissions from users that allow it to access the user’s device data as summarized here and described within this document.

personal data processed: biometric data access permission; camera permission; contacts permission; photo library permission; precise location permission (continuous).

location-based interactions

geolocation (this application)

this application may collect, use, and share user location data in order to provide location-based services.
 most browsers and devices provide tools to opt out from this feature by default. if explicit authorization has been provided, the user’s location data may be tracked by this application.

personal data processed: geographic position.

registration and authentication provided directly by this application

by registering or authenticating, users allow this application to identify them and give them access to dedicated services. the personal data is collected and stored for registration or identification purposes only. the data collected are only those necessary for the provision of the service requested by the users.

direct registration (this application)

the user registers by filling out the registration form and providing the personal data directly to this application.

personal data processed: budget; city; country; date of birth; email address; field of activity; first name; gender; house number; language; last name; password; phone number; physical address; picture; prefix ; profession; profile picture; usage data; username; various types of data; zip/postal code.

social features

firebase dynamic links (google llc)

firebase dynamic links is a social feature provided by google llc. dynamic links are tracked within firebase or google analytics for firebase, which informs the owner about the details of the user journey to and within this application.

personal data processed: various types of data as specified in the privacy policy of the service.

place of processing: united states – privacy policy.

further information about personal data

push notifications

this application may send push notifications to the user to achieve the purposes outlined in this privacy policy.

users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this application, some or all of the apps on the particular device.
 users must be aware that disabling push notifications may negatively affect the utility of this application.

access the address book

this application may request access to your address book.

the rights of users

users may exercise certain rights regarding their data processed by the owner.

users entitled to broader protection standards may exercise any of the rights described below. in all other cases, users may inquire with the owner to find out which rights apply to them.

in particular, users have the right to do the following:

• withdraw their consent at any time. users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.

• object to processing of their data. users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. further details are provided in the dedicated section below.

• access their data. users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.

• verify and seek rectification. users have the right to verify the accuracy of their data and ask for it to be updated or corrected.

• restrict the processing of their data. users have the right, under certain circumstances, to restrict the processing of their data. in this case, the owner will not process their data for any purpose other than storing it.

• have their personal data deleted or otherwise removed. users have the right, under certain circumstances, to obtain the erasure of their data from the owner.

• receive their data and have it transferred to another controller. users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. this provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract which the user is part of or on pre-contractual obligations thereof.

details about the right to object to processing

where personal data is processed for a public interest, in the exercise of an official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.

users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. to learn, whether the owner is processing personal data for direct marketing purposes, users may refer to the relevant sections of this document.

how to exercise these rights

any requests to exercise user rights can be directed to the owner through the contact details provided in this document. these requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month.

additional information about data collection and processing

additional information about user’s personal data

in addition to the information contained in this privacy policy, this application may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

system logs and maintenance

for operation and maintenance purposes, this application and any third-party services may collect files that record interaction with this application (system logs) use other personal data (such as the ip address) for this purpose.

information not contained in this policy

more details concerning the collection or processing of personal data may be requested from the owner at any time. please see the contact information at the beginning of this document.

how “do not track” requests are handled

this application does not support “do not track” requests.
 to determine whether any of the third-party services it uses honor the “do not track” requests, please read their privacy policies.

definitions and legal references

personal data (or data)

any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

usage data

information collected automatically through this application (or third-party services employed in this application), which can include: the ip addresses or domain names of the computers utilized by the users who use this application, the uri addresses (uniform resource identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the application) and the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user’s it environment.

user

the individual using this application who, unless otherwise specified, coincides with the data subject.

data subject

the natural person to whom the personal data refers.

data processor (or data supervisor)

the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this privacy policy.

data controller (or owner)

the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this application. the data controller, unless otherwise specified, is the owner of this application.

this application

the means by which the personal data of the user is collected and processed.

service

the service provided by this application as described in the relative terms (if available) and on this site/application.

cookie

cookies are trackers consisting of small sets of data stored in the user’s browser.

tracker

tracker indicates any technology – e.g cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of users, for example by accessing or storing information on the user’s device.

children’s privacy policy

we take the privacy of minors very seriously. please make sure that you as the parent who accepts these terms on behalf of the minor, supervise the types of data that the minor shares with us. to make sure data shared by minors is safe, we may (from time to time) integrate new mechanisms and safeguards on our platform.

in addition, parents or guardians can contact us to:

• direct us to delete the personal information we collected about their child;

• direct us to stop collecting or using personal information regarding their child; and

• prohibit the disclosure of personal information regarding their child to third parties not needed to provide the service.

during the registration process to create a primary account for use of zywa services, we first ask the individual attempting to register whether they are a parent/guardian or a child, then we ask the individual for their date of birth.  if the date of birth indicates that the individual is a child younger than 13, then the child will need a parent or guardian to create an account, and the child is shown a message to tell their parent or guardian about zywa and have their parent download the zywa app.  in addition, the registration session ends for that individual, we do not retain the birthdate information and no further registration information is collected.  if the individual is 13 years or older but younger than 18, then we will request the minor to provide a first and last name, an email address and password, and a parent’s cell phone number so that we can provide the parent with information about how to download the zywa app and finish registering an account.

we request, via digital consent during the registration process, that the parent or legal guardian establishing sub-accounts represent that they are the parent or legal guardian of minors under the age of 13 for whom the account is established and that they consent to our collection and use of the child’s personal information in accordance with our privacy policy.

when a parent or legal guardian decides to add a child as a sub-account, they provide us with the first and last name, and mobile phone number, if any, of a child under 13 in order to establish the child as a sub-account cardholder. the child is then invited to download the zywa app from the apple® app store or google® play and, upon doing so, are requested to enter an email address, password, date of birth and preferred pronoun.  once a child under 13 starts using the zywa app, we collect and maintain transaction data and history from our prepaid card services in order to provide zywa services to them.

parents and legal guardians can access personal information of a child under 13 at their own election from the account family’s dashboard. we do not exchange your personal information for money with anyone so that they can license or sell the personal information to additional parties.

data security practices

the owner uses appropriate technical and organizational security measures to ensure a level of protection to your personal data which is commensurate to the risk, taking into account state of the art technologies, implementation costs and the nature, scope, context and purposes of processing as well as the risk of likelihood and the degree of risk. the transfer of personal data between your end device and us is generally carried out in an encrypted form (tls encryption). user can identify an encrypted connection by the lock symbol in the address line of the user’s browser. users can communicate with us by email, access by third parties cannot be ruled out. in the case of confidential information, we recommend using encrypted email communication (pgp).

updates to this notice

the owner may occasionally update this policy. use of our services after an update constitutes consent to the updated notice to the extent permitted by law. if the owner make significant changes, they will notify you of such changes in advance. please take the time to periodically review this policy for the latest information on our privacy practices. should the changes affect processing activities performed on the basis of the user’s consent, the owner shall collect new consent from the user, where required.

this application collects some personal data from its users. users may be subject to different protection standards and broader standards may therefore apply to some. in order to learn more about the protection criteria, users can refer to the applicability section. we may revise this policy as well as update our services and the platform from time to time, so please keep visiting this page regularly to take notice of any changes we make. if you do not agree with any part of this policy, please stop using our services immediately.

owner and data controller

zywa technologies ltd difc, dubai, united arab emirates

owner contact email: care@zywa.co

types of data collected

among the types of personal data that this application collects, by itself or through third parties, there are: camera permission; precise location permission (continuous); biometric data access permission; photo library permission; tracker; usage data; unique device identifiers for advertising (google advertiser id or idfa, for example); device information; geography/region; number of users ; number of sessions; session duration; application opens; application updates; launches; operating systems; geographic position; first name; last name; gender; date of birth; phone number; physical address; email address; username; password; profession; country; zip/postal code; city; picture; prefix ; profile picture; budget; field of activity; house number; language; various types of data.

complete details on each type of personal data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the data collection. personal data may be freely provided by the user, or, in case of usage data, collected automatically when using this application. unless specified otherwise, all data requested by this application is mandatory and failure to provide this data may make it impossible for this application to provide its services. in cases where this application specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the service. users who are uncertain about which personal data is mandatory are welcome to contact the owner. any use of cookies – or of other tracking tools – by this application or by the owners of third-party services used by this application serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the cookie policy, if available. users are responsible for any third-party personal data obtained, published or shared through this application and confirm that they have the third party’s consent to provide the data to the owner.

mode and place of processing the data

methods of processing

the owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data. the data processing is carried out using computers and/or it enabled tools, following organizational procedures and modes strictly related to the purposes indicated. in addition to the owner, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, it companies, communications agencies) appointed, if necessary, as data processors by the owner.

the updated list of these parties may be requested from the owner at any time.

place

the data is processed at the owner’s operating offices and in any other places where the parties involved in the processing are located. depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. to find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal data. if any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with the owner using the information provided in the contact section.

retention time

personal data shall be processed and stored for as long as required by the purpose they have been collected for.

therefore:

• personal data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.

• personal data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.

the owner may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn.

furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

 once the retention period expires, personal data shall be deleted. therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

the purposes of processing

the data concerning the user is collected to allow the owner to provide its service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its users or third parties), detect any malicious or fraudulent activity, as well as the following: device permissions for personal data access, social features, analytics, beta testing, location-based interactions and registration and authentication provided directly by this application.

for specific information about the personal data used for each purpose, the user may refer to the section “detailed information on the processing of personal data”.

device permissions for personal data access

depending on the user’s specific device, this application may request certain permissions that allow it to access the user’s device data as described below.

by default, these permissions must be granted by the user before the respective information can be accessed. once the permission has been given, it can be revoked by the user at any time. in order to revoke these permissions, users may refer to the device settings or contact the owner for support at the contact details provided in the present document.
 the exact procedure for controlling app permissions may be dependent on the user’s device and software.

please note that the revoking of such permissions might impact the proper functioning of this application.

if user grants any of the permissions listed below, the respective personal data may be processed (i.e accessed to, modified or removed) by this application.

biometric data access permission

used for accessing the user’s biometrical data and/or authentication systems, such as for instance, faceid.

contact list permission
we allow users to discover their contacts on zywa’s platform. we require this permission to sync their contacts. syncing of contacts is an action that is optional, and is manually triggered by the user

camera permission

used for accessing the camera or capturing images and video from the device.

photo library permission

allows access to the user’s photo library.

precise location permission (continuous)

used for accessing the user’s precise device location. this application may collect, use, and share user location data in order to provide location-based services.

detailed information on the processing of personal data

personal data is collected for the following purposes and using the following services:

analytics

the services contained in this section enable the owner to monitor and analyze web traffic and can be used to keep track of user behavior.

google analytics for firebase (google llc)

google analytics for firebase or firebase analytics is an analytics service provided by google llc.
in order to understand google’s use of data, consult google’s partner policy.

firebase analytics may share data with other tools provided by firebase, such as crash reporting, authentication, remote config or notifications. the user may check this privacy policy to find a detailed explanation about the other tools used by the owner.

this application uses identifiers for mobile devices and technologies similar to cookies to run the firebase analytics service.

users may opt-out of certain firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other firebase related sections of this privacy policy, if available.

personal data processed: application opens; application updates; device information; geography/region; launches; number of sessions; number of users ; operating systems; session duration; tracker; unique device identifiers for advertising (google advertiser id or idfa, for example); usage data.

place of processing: united states – privacy policy.

beta testing

this type of service makes it possible to manage user access to this application, or parts of it, for the purpose of testing a certain feature or the entire application.
 the service provider may automatically collect data related to crashes and statistics related to the user’s use of this application in a personally identifiable form.

google play beta testing (google llc)

google play beta testing is a beta testing service provided by google llc.

personal data processed: usage data.

place of processing: united states – privacy policy.

testflight (apple inc.)

testflight is a beta testing service provided by apple inc.

personal data processed: device information; usage data.

place of processing: united states – privacy policy.

device permissions for personal data access

this application requests certain permissions from users that allow it to access the user’s device data as described below.

device permissions for personal data access (this application)

this application requests certain permissions from users that allow it to access the user’s device data as summarized here and described within this document.

personal data processed: biometric data access permission; camera permission; contacts permission; photo library permission; precise location permission (continuous).

location-based interactions

geolocation (this application)

this application may collect, use, and share user location data in order to provide location-based services.
 most browsers and devices provide tools to opt out from this feature by default. if explicit authorization has been provided, the user’s location data may be tracked by this application.

personal data processed: geographic position.

registration and authentication provided directly by this application

by registering or authenticating, users allow this application to identify them and give them access to dedicated services. the personal data is collected and stored for registration or identification purposes only. the data collected are only those necessary for the provision of the service requested by the users.

direct registration (this application)

the user registers by filling out the registration form and providing the personal data directly to this application.

personal data processed: budget; city; country; date of birth; email address; field of activity; first name; gender; house number; language; last name; password; phone number; physical address; picture; prefix ; profession; profile picture; usage data; username; various types of data; zip/postal code.

social features

firebase dynamic links (google llc)

firebase dynamic links is a social feature provided by google llc. dynamic links are tracked within firebase or google analytics for firebase, which informs the owner about the details of the user journey to and within this application.

personal data processed: various types of data as specified in the privacy policy of the service.

place of processing: united states – privacy policy.

further information about personal data

push notifications

this application may send push notifications to the user to achieve the purposes outlined in this privacy policy.

users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this application, some or all of the apps on the particular device.
 users must be aware that disabling push notifications may negatively affect the utility of this application.

access the address book

this application may request access to your address book.

the rights of users

users may exercise certain rights regarding their data processed by the owner.

users entitled to broader protection standards may exercise any of the rights described below. in all other cases, users may inquire with the owner to find out which rights apply to them.

in particular, users have the right to do the following:

• withdraw their consent at any time. users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.

• object to processing of their data. users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. further details are provided in the dedicated section below.

• access their data. users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.

• verify and seek rectification. users have the right to verify the accuracy of their data and ask for it to be updated or corrected.

• restrict the processing of their data. users have the right, under certain circumstances, to restrict the processing of their data. in this case, the owner will not process their data for any purpose other than storing it.

• have their personal data deleted or otherwise removed. users have the right, under certain circumstances, to obtain the erasure of their data from the owner.

• receive their data and have it transferred to another controller. users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. this provision is applicable provided that the data is processed by automated means and that the processing is based on the user’s consent, on a contract which the user is part of or on pre-contractual obligations thereof.

details about the right to object to processing

where personal data is processed for a public interest, in the exercise of an official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.

users must know that, however, should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. to learn, whether the owner is processing personal data for direct marketing purposes, users may refer to the relevant sections of this document.

how to exercise these rights

any requests to exercise user rights can be directed to the owner through the contact details provided in this document. these requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month.

additional information about data collection and processing

additional information about user’s personal data

in addition to the information contained in this privacy policy, this application may provide the user with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

system logs and maintenance

for operation and maintenance purposes, this application and any third-party services may collect files that record interaction with this application (system logs) use other personal data (such as the ip address) for this purpose.

information not contained in this policy

more details concerning the collection or processing of personal data may be requested from the owner at any time. please see the contact information at the beginning of this document.

how “do not track” requests are handled

this application does not support “do not track” requests.
 to determine whether any of the third-party services it uses honor the “do not track” requests, please read their privacy policies.

definitions and legal references

personal data (or data)

any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

usage data

information collected automatically through this application (or third-party services employed in this application), which can include: the ip addresses or domain names of the computers utilized by the users who use this application, the uri addresses (uniform resource identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the application) and the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user’s it environment.

user

the individual using this application who, unless otherwise specified, coincides with the data subject.

data subject

the natural person to whom the personal data refers.

data processor (or data supervisor)

the natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this privacy policy.

data controller (or owner)

the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this application. the data controller, unless otherwise specified, is the owner of this application.

this application

the means by which the personal data of the user is collected and processed.

service

the service provided by this application as described in the relative terms (if available) and on this site/application.

cookie

cookies are trackers consisting of small sets of data stored in the user’s browser.

tracker

tracker indicates any technology – e.g cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of users, for example by accessing or storing information on the user’s device.

children’s privacy policy

we take the privacy of minors very seriously. please make sure that you as the parent who accepts these terms on behalf of the minor, supervise the types of data that the minor shares with us. to make sure data shared by minors is safe, we may (from time to time) integrate new mechanisms and safeguards on our platform.

in addition, parents or guardians can contact us to:

• direct us to delete the personal information we collected about their child;

• direct us to stop collecting or using personal information regarding their child; and

• prohibit the disclosure of personal information regarding their child to third parties not needed to provide the service.

during the registration process to create a primary account for use of zywa services, we first ask the individual attempting to register whether they are a parent/guardian or a child, then we ask the individual for their date of birth.  if the date of birth indicates that the individual is a child younger than 13, then the child will need a parent or guardian to create an account, and the child is shown a message to tell their parent or guardian about zywa and have their parent download the zywa app.  in addition, the registration session ends for that individual, we do not retain the birthdate information and no further registration information is collected.  if the individual is 13 years or older but younger than 18, then we will request the minor to provide a first and last name, an email address and password, and a parent’s cell phone number so that we can provide the parent with information about how to download the zywa app and finish registering an account.

we request, via digital consent during the registration process, that the parent or legal guardian establishing sub-accounts represent that they are the parent or legal guardian of minors under the age of 13 for whom the account is established and that they consent to our collection and use of the child’s personal information in accordance with our privacy policy.

when a parent or legal guardian decides to add a child as a sub-account, they provide us with the first and last name, and mobile phone number, if any, of a child under 13 in order to establish the child as a sub-account cardholder. the child is then invited to download the zywa app from the apple® app store or google® play and, upon doing so, are requested to enter an email address, password, date of birth and preferred pronoun.  once a child under 13 starts using the zywa app, we collect and maintain transaction data and history from our prepaid card services in order to provide zywa services to them.

parents and legal guardians can access personal information of a child under 13 at their own election from the account family’s dashboard. we do not exchange your personal information for money with anyone so that they can license or sell the personal information to additional parties.

data security practices

the owner uses appropriate technical and organizational security measures to ensure a level of protection to your personal data which is commensurate to the risk, taking into account state of the art technologies, implementation costs and the nature, scope, context and purposes of processing as well as the risk of likelihood and the degree of risk. the transfer of personal data between your end device and us is generally carried out in an encrypted form (tls encryption). user can identify an encrypted connection by the lock symbol in the address line of the user’s browser. users can communicate with us by email, access by third parties cannot be ruled out. in the case of confidential information, we recommend using encrypted email communication (pgp).

updates to this notice

the owner may occasionally update this policy. use of our services after an update constitutes consent to the updated notice to the extent permitted by law. if the owner make significant changes, they will notify you of such changes in advance. please take the time to periodically review this policy for the latest information on our privacy practices. should the changes affect processing activities performed on the basis of the user’s consent, the owner shall collect new consent from the user, where required.