CNNEKT

Privacy Policy

We Will Never Share Your Data with Third Parties

Effective Date: January 01, 2024

Welcome!  At ZegaHabesha, your privacy is our priority. This Privacy Policy explains how we collect, store, protect, and share your information and with whom we share it. We recommend reading this in conjunction with our Terms and Conditions of Use.

WHO WE ARE

ZegaHabesha is a social networking platform operated by “15906881 Canada Inc.” (referred to as “we” or “us” in this policy), the controller of personal information collected and processed through the ZegaHabesha App and Sites. You can reach our Data Protection Team via email at DPT@cnnekt.com.

WHERE THIS PRIVACY POLICY APPLIES

This Privacy Policy applies to ZegaHabesha mobile applications (including the desktop version) (“App”), our websites, and microsites (such as zegahabesha.com).

COLLECTION OF INFORMATION

Registration Information: when you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, including:

    • Username
    • Email address
    • Mobile number
    • Gender identity
    • Date of birth
    • Sexual preference
    • Photographs
    • Location

    After registration, you have the flexibility to review and update your information anytime by logging into ZegaHabesha. However, please note that certain critical details, such as your Username, date of birth, and verified email/phone number, are restricted from modification. This restriction is in place to enhance security, prevent account recovery complications, and reduce the risk of spam and abuse. It remains your responsibility to ensure that your account details are accurate and up to date.

    The information we collect helps enhance the App and verify our Users. Registration Information, such as sexual preference, religion, name, and username, may be visible to other Users viewing your profile page.

    PROFILE INFORMATION

    We encourage you to think carefully about the information you disclose about yourself. While creating your profile, please be cautious about sharing sensitive information like email addresses, phone numbers, and credit card details, which can be open to abuse and misuse.

    PROFILE VERIFICATION INFORMATION

    To enhance user safety and security, we may request Users to verify their accounts. This verification process may include providing your phone number and performing photo verification. These measures help prevent the creation of fake accounts and malicious activities on the platform.

    PURCHASES INFORMATION

    For premium services, we process payment information securely for the prevention of fraud and audit/tax purposes. Automated decisions may block transactions that breach our Terms and Conditions of Use.

    GEOLOCATION INFORMATION

    If you’ve given ZegaHabesha access to your location, we collect information to personalize the App and enhance user interactions. You can control this access through your device settings.

    DEVICE INFORMATION

    We may collect device information, such as unique identifiers, device models, operating systems, and more, for various purposes outlined in this policy. App access to your device’s address book is solely for contact management.

    LINKS

    We monitor link interactions and may share aggregate click statistics.

    SUCCESS STORIES, SURVEYS & CONTRIBUTION

    We may run surveys for research and marketing purposes, contacting you based on your preferences.

    CUSTOMER SUPPORT

    Contacting Customer Support provides us with your email address and IP address for query resolution. Records are retained for 6 years after account deletion.

    COOKIES AND SIMILAR TECHNOLOGIES

    Cookies and similar technologies are used for data collection when using our Sites or App.

    USE OF YOUR INFORMATION

    Our goal is to provide an enjoyable experience on ZegaHabesha. We use your information to offer services, personalize content, conduct research, troubleshoot, and protect Users and third parties.

    MODERATION PRACTICES

    Automated systems and moderators monitor accounts and messages for Terms and Conditions breaches, enforcing access restrictions.

     DISCLAIMER

    This Privacy Policy is designed to provide insights into ZegaHabesha’s data collection, usage, and moderation practices, helping you understand how your information is handled when you use our services.

    LAWFUL BASIS

    Under EU and UK data protection laws, we are obligated to clarify the lawful basis for processing your data. The table below outlines these bases. For instances where the basis is consent, you can withdraw it at any time. In cases of legitimate interests as the basis, you can object to our data usage. In relevant sections of this Policy, we explain how to withdraw consent or opt out of specific data uses.

    Purpose Data Source Legal Basis
    To provide ZegaHabesha services Name, email address, date of birth, location (CCPA A, B) You provide info to us, and we obtain the location from the device Contractual necessity
    To facilitate networking on the App Profile information, including optional data (CCPA C, H, I, J) You provide info to us Consent
    To verify identity and prevent fraud Phone number, verification photo, device data (CCPA A, B, C, F, G, H) You provide info, we obtain device data Legitimate interests
    To process payment for premium services Payment card details (CCPA B, D) You provide payment info to us Contractual necessity
    To send marketing info Email address, mobile number (CCPA B) You provide contact info to us Consent
    To show nearby Users Location data (with permission) (CCPA G) The device provides location data (with permission) Legitimate interests
    To improve the App through research Log and usage data, images, and videos (CCPA F, H) You provide media, device provides usage data Legitimate interests
    To respond to queries Email address, IP address, social media info (CCPA B, F) You provide contact info to us, we obtain IP from the device Legitimate interests
    To block accounts for anti-spam measures Account details, user info (CCPA B, F) You provide account info to us, we obtain data from the device Legitimate interests
    To investigate and block infringements User details, profile content, messages, photos (CCPA A, B, C, E, H) You provide info to us Legitimate interests
    To enable third-party login Data from third-party accounts (CCPA A, B, C, H) We obtain data from your connected accounts Legitimate interests
    To block fraudulent transactions Payment and account details (CCPA A, B, D) You provide info to us, we obtain data from interactions Legitimate interests
    To serve promo cards and ads on the App Profile data, age, gender, location (CCPA A, C, G) You provide info, device provides location data Legitimate interests
    To serve ads and measure effectiveness Visit and action data, IP address, age, gender, device ID (CCPA B, C, F, G, K) You provide age, gender; and the device provides data Consent
    To conduct surveys and marketing Email address, mobile number (CCPA B) You provide contact info to us Legitimate interests
    To enable video and audio functions Call data, images, video (CCPA F, H) Device provides data Legitimate interests*
    To defend legal claims and protect Relevant information as needed Directly from you, device, or third parties Legitimate interests

    *For Snap Lenses on Apple devices, data from the TrueDepth camera improves features but isn’t stored or shared.

    DISCLOSURE OF INFORMATION

    When and Why Your Data May Be Shared

    Disclosure Scenario Data Disclosed Description
    Service Providers All data (including all CCPA Categories) Trusted third parties who would be assisting us in various functions and services. More detail below.
    Moderators Name, user details, profile info, messages, photos (CCPA A, B, C, E, H) Monitor App activity and content approval.
    Payment Processors and Telecom Companies Payment details (CCPA A, B, D) Facilitate premium service payments.
    Law Enforcement and Safety All relevant data (including all CCPA Categories) Coordinating with law enforcement inquiries and investigations, complying with legal obligations.
    Business Transfers All personal data (including all CCPA Categories) In case of business transition or change of ownership.
    Marketing Services Providers Advertising ID, location, age, gender, visit/action data (CCPA B, C, G, F, K) Enhance marketing and ads on third-party sites.
    Aggregated Information Aggregated data (not identifying individuals directly) Sharing data for industry analysis and profiling.

     MORE INFORMATION ABOUT DISCLOSURES

    SHARING WITH SERVICE PROVIDERS

    We collaborate with reputable third-party Service Providers to provide various functions and services (‘Service Providers’). The choice of suppliers depends on User engagement with our Apps, Sites, and services. For instance, we often engage the following suppliers:

      • Billing services (e.g., Apple Store) for purchasing paid App features
      • Authentication services (e.g., Twilio) for account authentication only
      • Product enhancement, market research, and customer surveys
      • IT services for customer support inquiries

      Stringent due diligence on Service Providers ensures they meet data protection and security standards. Only necessary personal data is shared, with measures to ensure data anonymity. Contracts impose strict data retention limits and obligations on our suppliers.

      SHARING WITH MARKETING SERVICES PROVIDERS

      Periodically, we collaborate with Marketing Services Providers (e.g., Facebook) for third-party site ads and campaign effectiveness measurement. This can involve:

        • Excluding existing users from ads targeting new users
        • Displaying ads to users who visited the App/Sites but lack an account
        • Showing App feature ads to current users
        • Forming Lookalike Audiences or custom audiences based on user characteristics

        Limited personal data shared with Marketing Services Providers includes:

          • Advertising identifier associated with your device
          • Estimated location (IP address)
          • Age and gender
          • Data about your App/Site visit and actions

          Some platforms require user consent for advertising data use, and ZegaHabesha respects this. Device privacy settings allow control over sharing device identifiers with third-party advertisers.

          In all cases, data sharing is compliant with data protection laws and protections. You can also withdraw your consent by adjusting your device’s privacy settings and contacting us as described in section 4 below.

          LINKS AND OTHER THIRD-PARTY SERVICES

          The App and Sites may contain links to third-party websites. Please be aware that ZegaHabesha is not responsible for the privacy practices of such other websites. We encourage our Users to be aware when they leave our Site and to read the privacy statements of each website that collects personally identifiable information. This Privacy Policy applies solely to information collected by us.

          YOUR CHOICES AND RIGHTS

          We understand the importance of having control over your personal data. In line with applicable data protection laws, you have the following rights:

          ACCESS AND DATA PORTABILITY

          You can access and receive your personal data by requesting a copy of your data in a structured, commonly used, and machine-readable format.

          ACCOUNT CLOSURE

          You can close your ZegaHabesha Account at any time. We’ll remove your public posts from view and delete your personal data.

          WITHDRAWING CONSENT

          You can withdraw your consent at any time by adjusting your device’s privacy settings or contacting us. Withdrawing consent does not affect data processing before consent withdrawal.

          OBJECTION TO PROCESSING

          Where applicable, you can object to data processing based on legitimate interests. We’ll cease processing unless compelling legitimate grounds override your interests or legal rights.

          UPDATING INFORMATION

          You can review, update, or correct your Registration Information and other data you provide through your Account settings.

          REQUEST DELETION

          You can request the deletion of personal data when it’s no longer required for the purposes for which it was collected or when processing is based on your consent, and you withdraw it.

          RESTRICTION OF PROCESSING

          You can ask us to restrict the processing of your personal data under certain conditions.

          LODGING A COMPLAINT

          You can lodge a complaint with a data protection authority about our data processing activities.

          EUROPEAN ECONOMIC AREA (EEA) RESIDENTS

          If you’re a resident of the EEA, you have additional rights, including:

            • The right to be informed about the personal data we process and how we process it.
            • The right to rectify inaccurate personal data.
            • The right to request that we erase your personal data.
            • The right to withdraw consent (where processing is based on consent)
            • The right to data portability.
            • The right to object to our processing of your personal data.
            • Rights related to automated decision-making, including profiling.

            If you wish to exercise any of these rights, please contact our Data Protection Team at DPT@cnnekt.com.

            DATA SECURITY AND RETENTION

            We prioritize your data’s security and employ industry-standard safeguards. However, no method of transmission over the Internet or electronic storage is entirely secure, so we cannot guarantee absolute security.

            We retain your personal data for as long as necessary to provide services and to fulfill the purposes for which it was collected. Data retention periods are determined by business needs and legal requirements.

            HOW TO EXERCISE YOUR RIGHTS

            To exercise your rights under this Policy, please contact our Data Protection Team at DPT@cnnekt.com.

            Please provide the email or phone number associated with your account and a detailed description of your data request. We’ll respond as soon as possible and within 72 hours unless the request is complex or numerous. In such cases, we may extend the response time by two more months and will inform you accordingly.

            CONTACT US

            If you have any questions about this Privacy Policy or our data processing activities, you can contact our Data Protection Team at DPT@cnnekt.com

            CHANGES TO THIS PRIVACY POLICY

            We may revise this Policy from time to time, so please review it frequently. If we make substantial changes, we will notify you by email or within the App as required by applicable law.