THE ZENE App
THE ZENE attaches great importance to the protection of personal data and collects, processes and uses personal data solely in accordance with the principles described below and in compliance with the applicable data protection provisions. THE ZENE is based in Switzerland and complies primarily with the Swiss Data Protection Act (FADP). If personal data is processed from people who have the right to rely on their own legal system–in particular on the EU General Data Protection Regulation (GDPR)–THE ZENE will also follow these rules, if applicable to THE ZENE, and grant these persons rights specific to their law.
Personal data is all information relating to an identified or identifiable natural person, which includes, for example, user’s name as well as user’s postal and email addresses.
1. Data controller for the operation of THE ZENE App
THE ZENE AG (CHE-493.907.970), Hertensteinstrasse 51, CH-6004 Luzern, Switzerland (“THE ZENE”) operates THE ZENE website as well as the software and mobile application THE ZENE (together: “THE ZENE App”) and collects, processes and uses personal data of users of THE ZENE App (“users”) solely for the implementation of this program.
THE ZENE AG, Hertensteinstrasse 51, CH-6004 Luzern, Switzerland E-Mail: email@example.com
THE ZENE AG representative in the EEA according to art. 27 GDPR is:
Jasmin Lieffering, LITC, Bärenmarsch 3, DE-31623 Drakenburg,
Users have the right to make a complaint at any time to the Federal Data Protection and Information Commissioner, the Swiss supervisory authority for data protection issues (http://www.edoeb.admin.ch). THE ZENE would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.
2. Data collection in connection with THE ZENE App
For the operation of THE ZENE App, to communicate and provide you our services, THE ZENE collects and saves the following personal data in a central customer database:
2.1 Data collected by THE ZENE App
(1) Information given by the users
THE ZENE collects content and personal data if the user uses THE ZENE App. For example, when a user signs up for an account or messages or communicates with others, including THE ZENE itself (support or any artificial intelligence tool integrated in THE ZENE App), users may give THE ZENE information. This personal data is including, but not limited the users name, username, email address, phone number, address, birth date, contact preferences, photos and gender plus any data provided voluntarily by the users of THE ZENE App.
(2) Information THE ZENE gets from the use of THE ZENE App
THE ZENE collects information to provide the users with the functionality of THE ZENE App, to improve the user’s experience using THE ZENE App and to develop new functionalities and services in and to THE ZENE App. To do this, THE ZENE collects information about how the users use THE ZENE App and other online products and services that might be available by THE ZENE. In some cases, this information will be associated with the user’s personal and/or other information. For example:
- Device information: THE ZENE collects device-specific information such as the user’s hardware model, operating system version, unique device identifiers and mobile network information including phone number if applicable.
- Log information: When users use THE ZENE App, THE ZENE automatically collects and stores certain information including details of how THE ZENE App is used, such as the date and time a message was sent, the account the users were messaging with, and the user’s internet protocol address, as well as third-party websites or services the users used.
- Friend information: If users use the chat option of THE ZENE App, THE ZENE may use the information from the user’s mobile device’s address book from time to time to connect the users with friends and to allow other friends who have the user in their address book to find the user. In addition, THE ZENE stores information of the user’s friends in THE ZENE App.
- Bot chats: If the user chats with bots made by THE ZENE, THE ZENE collects the contents of the conversation to improve the user experience and THE ZENE App or to create new ones.
- Local storage: THE ZENE may collect and store information locally on the user’s device using mechanisms such as browser web storage (including HTML 5) and application data caches.
- Tracking ID’s and similar technologies: THE ZENE or its service providers (such as tracking ID and analytics providers) may collect, store or recognize some information on the user’s device from technologies including, but not limited to cookies and web beacons.
(3) Google Analytics
Further information concerning the terms and conditions of use and data privacy can be found at http://www.google.com/analytics/terms or at https://www.google.com/intl/analytics/policies/privacy/.
3. Purpose of Data Processing and Legal Grounds
The data stated under Section 2 is used by THE ZENE for the following purposes:
(1) Provide, improve and develop the Services and THE ZENE App including provide you with our Service, including, but not limited to, helping you view, explore, and create NFTs using our tools and, at your own discretion, connect directly with others to purchase, sell, or transfer NFTs on public blockchains.
THE ZENE will use your personal information such as your username in connection with the NFT’s that are currently or were previously accessible in your third-party wallet. THE ZENE may send you notifications related to actions on the NFT services, including potential offers on your NFT’s and will use the user’s contact information to enable the third-party provider to get in touch with the user.
(2) THE ZENE uses the collected information to deliver and enhance its services and to improve THE ZENE App, to personalize content, and to make suggestions to the users. For example, THE ZENE uses some registration information to: (a) set up a profile page for the user; and (b) help connect the user with friends in THE ZENE App–if a THE ZENE App user has another’s user email or phone number in their phone contacts and uses the suggested friend feature, that person can start chatting with the user and may see the users profile page. THE ZENE processes personal data for these purposes based on THE ZENE’s legitimate interest and based on the performance of a contract. Communicate with the users
The information THE ZENE collects lets THE ZENE keep the user posted on THE ZENE’s latest announcements, software updates, and messages by THE ZENE (opt out function provided). THE ZENE processes personal data for these purposes based on THE ZENE’s legitimate interest and based on the performance of a contract.
(3) Show and measure ads and Services
THE ZENE might use information for advertising purposes and to improve its advertising and measurement systems so that THE ZENE can show the user relevant ads on THE ZENE App and measure the effectiveness and reach of the ads and services.
Promote Safety and Security: THE ZENE may use the user’s information, including date of birth, to verify identity, to determine eligibility to use THE ZENE App, and to recommend appropriate services. THE ZENE may also use information for loss prevention and anti-fraud purposes and to enforce its Terms and Conditions. THE ZENE processes personal data for these purposes based on THE ZENE’s legitimate interest and based on the performance of a contract.
(4) Further Information
If a user has given THE ZENE his or her relevant consent, THE ZENE may send the user further information about THE ZENE, product information and exclusive offers by email and/or by post. Consent can be revoked at any time. Based on the data collected, THE ZENE may personalize the information sent to the user so that the user particularly receives, where possible, information which THE ZENE deems interesting for the relevant user. For this purpose, THE ZENE analyses the data collected and, in particular, takes account of the saved information relating to age, sex, usage of THE ZENE App, as well as other information that can be gleaned from the collected data. THE ZENE processes personal data for these purposes based on THE ZENE’s legitimate interest.
4. Data Retention
THE ZENE will only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of compliance with any legal, regulatory, tax, accounting or reporting requirements. THE ZENE will keep the necessary data for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations under applicable laws.
As soon as the user’s personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. THE ZENE may delete or terminate accounts that are inactive (i.e., not logged into) for 180 Days.
5. Data Security
THE ZENE has put in place appropriate technical and organizational security procedures to prevent personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, THE ZENE limits access to user’s personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on THE ZENE instructions, and they are subject to a duty of confidentiality. Furthermore, THE ZENE has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where THE ZENE is legally required to do so. Nevertheless, a user should always be aware that the transmission of data over the Internet and other electronic means entails certain security risks, and that THE ZENE cannot give any guarantee for the security of data that are transmitted in this way.
6. Data processing
The central database, in which all collected data described in Section 2 is saved, is operated on behalf of and in accordance with THE ZENE’s instructions in Germany. THE ZENE is the controller under data protection law and ensures compliance with the provisions of data protection law and the requisite security measures in the context of contract data processing.
7. Third-Party links
8. Information on the user’s rights
Under certain circumstances, users have rights under applicable data protection laws in relation to their personal data. Users may have the right to access, rectification and erasure of their personal data, the right to restriction of processing, or to object to our data processing in addition to the right to receive certain personal data for transfer to another controller (data portability).
If a user wishes to exercise any of the rights set out above, he/she can contact THE ZENE AG, as the controller, by using the contact information mentioned in Section 1.
9. Right of revocation
Insofar as the users of THE ZENE App have given their consent for their data to be used for advertising purposes, they may revoke this consent with future effect at any time and free of charge by contacting email or for Newsletter by clicking on the unsubscribe button.
10. Corporate Mergers
In the event that THE ZENE merges, acquires, restructures, sells, becomes bankrupt or involved in any such transaction, THE ZENE may sell, transfer or transfer assets, including user information, in connection with such transaction or in consideration of such transaction (e.g., due diligence). Within the scope of the examination (e.g. due diligence) of such a transaction, THE ZENE has a legitimate interest in making certain personal data accessible to an interested party. If personal data from users is transferred to a new controller as part of such a transaction, THE ZENE will inform the users in advance and grant them an opt-out right. If a user makes use of such a right, THE ZENE cannot guarantee that a user will be able to continue and to make full use of THE ZENE services.