Data Policy for European Users
Last modified: 05/10/2023
This Data Policy describes how Znugle Technology AB. and its affiliates (“we,” “us,” or “Znugle”), process personal information that we collect through the Znugle Platform. Depending on where you live and what you are doing on the Znugle Platform, the supplemental pages listed below may apply to you. Please review the supplemental pages with information about how we process personal information for those regions and services including: (i) the controller(s) of your personal information; (ii) legal bases, including legitimate interests, for collecting and processing your personal information, (iii) safeguards relied upon for transferring personal information outside the EEA; (iv) your rights, and (v) contact details of the controller(s) and Data Protection Officer.
1. Definitions
Undefined terms in this Data Policy have the same definition as in our Terms of Service (“Terms”).
2. Personal Information We Collect
2.1 Information Needed to Use the Znugle Platform. We collect personal information about you when you use the Znugle Platform. Without it, we may not be able to provide you with all services requested. This information includes:
• Contact Information. Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.
2.2 Information You Choose to Give Us. You can choose to provide us with additional personal information. This information may include:
• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.
2.3 Information Automatically Collected by Using the Znugle Platform and Our Payment Services. When you use the Znugle Platform and Payment Services, we automatically collect personal information. This information may include:
• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, contracts you have made, and other actions on the Znugle Platform.
• Log Data and Device Information. Such as details about how you’ve used the Znugle Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Znugle Platform. We may collect this information even if you haven’t created a Znugle account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address and other related transaction details.
2.4 Personal Information We Collect from Third Parties. We collect personal information from other sources, such as:
• Third party Services. If you link, connect, or login to the Znugle Platform with a third party service (e.g. Apple, Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals. If you are invited to the Znugle Platform, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Znugle Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.
• Contact Information. Account, Profile Information. Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.
• Identity Verification and Payment Information. Such as images of your government issued ID (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.
2.2 Information You Choose to Give Us. You can choose to provide us with additional personal information. This information may include:
• Additional Profile Information. Such as gender, preferred language(s), city, and personal description. Some of this information as indicated in your account settings is part of your public profile page and will be publicly visible.
• Address Book Contact Information. Address book contacts you import or enter manually.
• Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Members, or share your experience with us. This may include health information if you choose to share it with us.
2.3 Information Automatically Collected by Using the Znugle Platform and Our Payment Services. When you use the Znugle Platform and Payment Services, we automatically collect personal information. This information may include:
• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for Listings, contracts you have made, and other actions on the Znugle Platform.
• Log Data and Device Information. Such as details about how you’ve used the Znugle Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Znugle Platform. We may collect this information even if you haven’t created a Znugle account or logged in.
• Cookies and Similar Technologies as described in our Cookie Policy.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address and other related transaction details.
2.4 Personal Information We Collect from Third Parties. We collect personal information from other sources, such as:
• Third party Services. If you link, connect, or login to the Znugle Platform with a third party service (e.g. Apple, Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.
• Referrals. If you are invited to the Znugle Platform, the person who invited you can submit personal information about you such as your email address or other contact information.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Znugle Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.
3. How We Use Information We Collect
If you reside in the European Economic Area (“EEA”), click here to learn about our legal bases for collection and processing personal information. We use personal information as outlined in this Data Policy.
3.1 Provide, Improve, and Develop the Znugle Platform. We use personal information to:
• enable you to access the Znugle Platform and make and receive payments,
• enable you to communicate with other Members,
• perform analytics, debug and conduct research,
• provide customer service,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information such as your friends, we may process this information: (i) to facilitate your referral invitations, (ii) to share your contract details, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Znugle Platform, your search and activity history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.
3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:
• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• study and combat discrimination,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees and members of the public,
• resolve disputes with our Members,
• enforce our contracts with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights,
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Znugle Platform, your profile information and other content you submit to Znugle, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Znugle Platform if such processes detect activity that we think poses a safety or other risk to Znugle, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us.
3.3 Provide, Personalize, Measure, and Improve Our Advertising and Marketing. We may use personal information to:
• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Znugle or its third party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.
3.4 Provide Payment Services. Personal information is used to enable or authorize third parties to use Payment Services:
• Detect and prevent money laundering, fraud, abuse, security incidents.
• Conduct security investigations and risk assessments.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
• Provide and improve the Payment Services.
• enable you to access the Znugle Platform and make and receive payments,
• enable you to communicate with other Members,
• perform analytics, debug and conduct research,
• provide customer service,
• send you messages, updates, security alerts, and account notifications,
• if you provide us with your contacts’ information such as your friends, we may process this information: (i) to facilitate your referral invitations, (ii) to share your contract details, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,
• personalize and customize your experience based on your interactions with the Znugle Platform, your search and activity history, your profile information and preferences, and other content you submit, and
• enable your use of our enterprise products.
3.2 Create and Maintain a Trusted and Safer Environment. We use personal information to:
• detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
• study and combat discrimination,
• conduct security investigations and risk assessments,
• verify or authenticate information provided by you,
• conduct checks against databases and other information sources, including background or police checks,
• comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Hosts’ employees and members of the public,
• resolve disputes with our Members,
• enforce our contracts with third parties,
• comply with law, respond to legal requests, prevent harm and protect our rights,
• enforce our Terms and other policies, and
• in connection with the activities above, we may conduct profiling based on your interactions with the Znugle Platform, your profile information and other content you submit to Znugle, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Znugle Platform if such processes detect activity that we think poses a safety or other risk to Znugle, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us.
3.3 Provide, Personalize, Measure, and Improve Our Advertising and Marketing. We may use personal information to:
• send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
• personalize, measure, and improve our advertising,
• administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Znugle or its third party partners,
• analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you, and
• invite you to events and relevant opportunities.
3.4 Provide Payment Services. Personal information is used to enable or authorize third parties to use Payment Services:
• Detect and prevent money laundering, fraud, abuse, security incidents.
• Conduct security investigations and risk assessments.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.
• With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
• Provide and improve the Payment Services.
4. Sharing and Disclosure
If you reside in the EEA, learn about safeguards we rely on for transferring personal information to recipients outside of the EEA here.
4.1 Sharing with Your Consent or at Your Direction. Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third party application or website to access your Znugle account or participating in promotional activities by Znugle partners or third parties. Where permissible with applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Znugle or otherwise promote our products and services.
4.2 Sharing Between Members. To help facilitate contracts or other interactions between Members, we may need to share certain information such as:
• When a contract request is made or dispute is submitted, certain information may be shared between Guest(s) and Host(s), including profile, name, names of any additional Guests, rental history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a contract is confirmed, additional information is shared to assist with coordinating the contract, like profile photo and phone number. When you as a Host have a confirmed contract, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the contract, such as your profile, full name, phone number, and Listing address.
• When you as a Host invite another Member to host with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Listing address, calendar, Listing information, Listing photos, and email address.
• When you as a Guest invite additional Guests to a contract, your full name, contract dates, Host name, Listing details, the Listing address, and other related information will be shared with each additional Guest.
4.3 Information You Publish in Profiles, Listings, and other Public Information. You can make certain information publicly visible to others, such as:
• Your public profile page, which includes your profile photo, name, description, and city.
• Listing pages that include information such as the Listing approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings and other public feedback.
• Content in a community or discussion forum, blog or social media post.
We may display parts of your public profile and other Content you make available to the public like Listing details on third party sites, platforms and apps. Information you share publicly on the Znugle Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your account settings.
4.4 Host Service Providers. Hosts may use third party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Znugle Platform to share information about the Guest (like contract start and end dates, Guest name, Guest phone number) with such third party service providers.
4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Znugle, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our Members to legal or regulatory liability, (iv) to enforce and administer our contracts with Members, or (v) to protect the rights, property or personal safety of Znugle, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Znugle, our Members, or expose Znugle to a claim of obstruction of justice.
For jurisdictions where Znugle facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, contracts, Listings and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.
In jurisdictions where Znugle facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Znugle in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Listing address, tax identification number, Listing details, and rental dates.
4.6 Programs with Managers and Owners. We may share personal information of Hosts and Guests such as contract information, and information related to compliance with applicable laws such as short-term and long-term rental laws with landlords, management companies, and/or property owners (the “Building Management”), in order to facilitate programs with Building Management. For example, guest contract and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located, to facilitate hosting services, compliance with applicable laws, security, billing, and other services.
4.7 Host Information Provided to Znugle for Work Customers. If a contract is designated as being for business or work purpose and (i) is made by a Guest affiliated with an Enterprise, (ii) the Enterprise is enrolled in Znugle for Work, we may disclose information related to the contract to the Enterprise (e.g., name of the Host, Listing address, rental dates, Listing details, etc.) to the extent necessary for the adequate performance of Znugle’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.
4.8 Service Providers. We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Znugle Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Znugle’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.
4.9 Business Transfers. If Znugle undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different Data Policy.
4.10 Corporate Affiliates. To support us in providing, integrating, promoting and improving the Znugle Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control.
4.2 Sharing Between Members. To help facilitate contracts or other interactions between Members, we may need to share certain information such as:
• When a contract request is made or dispute is submitted, certain information may be shared between Guest(s) and Host(s), including profile, name, names of any additional Guests, rental history, review information, age of guest (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a contract is confirmed, additional information is shared to assist with coordinating the contract, like profile photo and phone number. When you as a Host have a confirmed contract, certain information is shared with the Guest (and the additional Guests they invite, if applicable) to coordinate the contract, such as your profile, full name, phone number, and Listing address.
• When you as a Host invite another Member to host with you, you authorize that person to access and update your information and Member Content, including but not limited to certain information like your full name, phone number, Listing address, calendar, Listing information, Listing photos, and email address.
• When you as a Guest invite additional Guests to a contract, your full name, contract dates, Host name, Listing details, the Listing address, and other related information will be shared with each additional Guest.
4.3 Information You Publish in Profiles, Listings, and other Public Information. You can make certain information publicly visible to others, such as:
• Your public profile page, which includes your profile photo, name, description, and city.
• Listing pages that include information such as the Listing approximate or precise location description, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
• Reviews, ratings and other public feedback.
• Content in a community or discussion forum, blog or social media post.
We may display parts of your public profile and other Content you make available to the public like Listing details on third party sites, platforms and apps. Information you share publicly on the Znugle Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your account settings.
4.4 Host Service Providers. Hosts may use third party services to help manage or deliver their services, such as cleaning services or lock providers. Hosts may use features on the Znugle Platform to share information about the Guest (like contract start and end dates, Guest name, Guest phone number) with such third party service providers.
4.5 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights. We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Znugle, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our Members to legal or regulatory liability, (iv) to enforce and administer our contracts with Members, or (v) to protect the rights, property or personal safety of Znugle, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, Host tax information may be shared with tax authorities or other governmental agencies.
Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Znugle, our Members, or expose Znugle to a claim of obstruction of justice.
For jurisdictions where Znugle facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose Hosts’ and Guests’ information about transactions, contracts, Listings and occupancy Taxes to the applicable tax authority, such as Host and Guest names, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.
In jurisdictions where Znugle facilitates or requires a registration, notification, permit, or license application of a Host with a local governmental authority through Znugle in accordance with local law, we may share information of participating Hosts with the relevant authority, both during the application process and, periodically thereafter, such as the Host’s full name and contact details, Listing address, tax identification number, Listing details, and rental dates.
4.6 Programs with Managers and Owners. We may share personal information of Hosts and Guests such as contract information, and information related to compliance with applicable laws such as short-term and long-term rental laws with landlords, management companies, and/or property owners (the “Building Management”), in order to facilitate programs with Building Management. For example, guest contract and personal information, including guest contact information, may be shared with the Building Management of the building, complex, or community where a host lives and/or the listing is located, to facilitate hosting services, compliance with applicable laws, security, billing, and other services.
4.7 Host Information Provided to Znugle for Work Customers. If a contract is designated as being for business or work purpose and (i) is made by a Guest affiliated with an Enterprise, (ii) the Enterprise is enrolled in Znugle for Work, we may disclose information related to the contract to the Enterprise (e.g., name of the Host, Listing address, rental dates, Listing details, etc.) to the extent necessary for the adequate performance of Znugle’s contract with the Enterprise and to provide the services. At the request of the Enterprise or the Guest, we may also share this information with third parties engaged by the Enterprise to provide support services.
4.8 Service Providers. We share personal information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Znugle Services through third party platforms and software tools (e.g. through the integration with our APIs), (vi) provide customer service, advertising, or payments services, (vii) process, handle or assess insurance claims or similar claims, or (viii) facilitate non-profit and charitable activities consistent with Znugle’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.
4.9 Business Transfers. If Znugle undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different Data Policy.
4.10 Corporate Affiliates. To support us in providing, integrating, promoting and improving the Znugle Platform, Payment Services, and our affiliates’ services, we may share personal information within our corporate family of companies that are related by common ownership or control.
5. Other Important Information
5.1 Analyzing Your Communications. We may review, scan, or analyze your communications on the Znugle Platform for reasons outlined in the “How We Use Information We Collect” section of this Data Policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other sites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you and we will not sell reviews or analyses of these communications.
5.2 Linking Third Party Accounts. You can link your Znugle account with certain third party services like social networks. Your contacts on these third party services are referred to as “Friends.” When you direct the data sharing by creating this link:
• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Znugle Platform may be displayed to your Friends on the Znugle Platform and/or that third party service,
• a link to your public profile on that third party service may be included in your Znugle public profile,
• other Znugle users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Znugle users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Znugle Platform through this linkage is subject to your settings and authorizations on the Znugle Platform and the third party service.
5.3 Third Party Partners and Integrations. Parts of Znugle may link to third party services, not owned or controlled by Znugle, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information). Znugle does not own or control these third parties and when you interact with them you are providing your information to them.
5.2 Linking Third Party Accounts. You can link your Znugle account with certain third party services like social networks. Your contacts on these third party services are referred to as “Friends.” When you direct the data sharing by creating this link:
• some of the information provided to us from linking accounts may be published on your public profile,
• your activities on the Znugle Platform may be displayed to your Friends on the Znugle Platform and/or that third party service,
• a link to your public profile on that third party service may be included in your Znugle public profile,
• other Znugle users may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
• other Znugle users may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
• information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
• publication and display of information that you provide to the Znugle Platform through this linkage is subject to your settings and authorizations on the Znugle Platform and the third party service.
5.3 Third Party Partners and Integrations. Parts of Znugle may link to third party services, not owned or controlled by Znugle, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information). Znugle does not own or control these third parties and when you interact with them you are providing your information to them.
6. Your Rights
You can exercise any of the rights described in this section consistent with applicable law. Contact us for information on data subject rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking further action on your request. Learn more about rights under GDPR on the supplemental pages.
6.1 Managing Your Information. You can access and update some of your personal information through your Account settings. If you connected your Znugle Account to a third party service, like Apple, Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.
6.2 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Data Erasure. In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
• You may request deletion of your account at any time through the Settings > Account menu in the Znugle app, or you can send an account deletion request by contacting Znugle through the Get Help > Znugle Support menu in the Znugle app, or through Znugle’s website here.
• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Znugle Account for fraud or safety reasons, we may retain information from that Znugle Account to prevent that Member from opening a new Znugle Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Znugle and Znugle Payments may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Znugle, even after your Znugle Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
6.2 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).
6.3 Data Erasure. In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the erasure of your personal information:
• You may request deletion of your account at any time through the Settings > Account menu in the Znugle app, or you can send an account deletion request by contacting Znugle through the Get Help > Znugle Support menu in the Znugle app, or through Znugle’s website here.
• We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Znugle Account for fraud or safety reasons, we may retain information from that Znugle Account to prevent that Member from opening a new Znugle Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Znugle and Znugle Payments may keep information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Znugle, even after your Znugle Account is cancelled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
• Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
7. Security
While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.
8. Changes to This Data Policy
We reserve the right to modify this Data Policy at any time in accordance with applicable law. If we do so, we will post the revised Data Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Data Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Data Policy becomes effective, your continued access to or use of the Znugle Platform will be subject to the revised Data Policy.
9. Contact Information and Responsible Znugle Entities
For questions or complaints about this Data Policy or Znugle’s handling of personal information contact Znugle Technology AB.
Important Supplemental Information
If you reside in the European Economic Area (“EEA”) visit our “If you reside in the European Economic Area” page to learn about (i) the controller(s) of your personal information, (ii) legal bases, including legitimate interests, for collecting and processing your personal information, (iii) safeguards relied upon for transferring personal information outside the EEA, (iv) your rights, and (v) contact details of the controller(s) and Data Protection Officer.
