Privacy Policy​

1.1 Ezsy Privacy Protection Summary

1.1.1 What data we collect about you?

We collect information when you set up your ezsy account and use the services available within ezsy (such as posting photos to your Moments feed or following Official Accounts). To set up your account, we collect your nickname, mobile number, and a password. You can further refine and populate your profile with additional information.

1.1.2 How do we use your info?

We use your information to provide ezsy to you, allowing you to communicate with other users, and to use the features on ezsy. We use your information for account set-up, to facilitate communications, provide support, allow you to access features of ezsy, and to improve ezsy. ezsy uses contact channels provided by you, such as mobile number or email address, for verification and protecting your account and for important administrative reasons and for promotional or marketing of products or services that relate to and/or complement the existing features on ezsy.

1.1.3 Who do we share your data with?

We use third parties for support services, such as SMS service providers for account validation, mapping and points-of-interests services, translation services, and support services. We use these third party services solely to process or store your information for the purposes described in this policy. We also share your information with related companies of ezsy and as required by law. Aside from the previously mentioned purposes, ezsy does not share your data to third-parties without your prior explicit consent. Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in the this policy.

1.1.4 Where do we process your data?

Our servers are located in Singapore and Hong Kong. We also have support, engineering and other teams that support the provision of ezsy to you, located around the world. Your data may be accessed from such locations. Rigorous internal control measures are undertaken to strictly limit access to your data by designated team members.

1.1.5 How long do we keep hold of your data?

The time we retain your information for depends on the type of information – for example, log-in data is retained for as long as you remain an account holder on the ezsy app. If you instruct us to delete your ezsy account, your information is deleted within 60 days of the latter of verification of account ownership and receiving your account deletion request.

1.1.6 How can I exercise my rights over my data?

You may have special rights over your data and how we can use it. These include how you can access the data, erasing the data, restricting how your data can be used, objecting to its use, and getting a copy of your information.

1.1.7 How will we notify you of changes?

If there are any significant changes to this Privacy Policy, we will send you a notification before the change becomes effective. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at privacy@ezsy.com

1.1.8 Contact Information for Dispute Resolution

If you have any concerns or complaints, please contact us privacy@ezsy.com.

1.2 Ezsy Privacy Policy

1.2.1 INTRODUCTION

Welcome to ezsy!

We value your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us or that you generate in using ezsy.

The use of our services (being the ezsy mobile app, the website https://www.ezsy.com/ or any third party platforms through which ezsy is provided) (together,”ezsy”) involve the processing of your Information. It is important for you to understand how this happens and how you may control it.

Please read this Privacy Policy carefully.

By using ezsy you agree to the processing of your Information in accordance with this Privacy Policy.

When you use certain features you will be asked to agree to the processing of your Information in certain ways. For certain Information you may withdraw your agreement to the processing of that Information in accordance with this Privacy Policy.

If you do not agree with this Privacy Policy, you must not use ezsy.

If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer via email at privacy@ezsy.com (Attention: Data Protection Officer, Legal Department).

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to ezsy, as well as any services accessible on the ezsy platform that state that this Privacy Policy applies to the use of such service. Those ezsy services may have further privacy-related terms that you must agree to if you use those services. Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the ezsy Terms of Service, unless they are defined otherwise in this Privacy Policy.

Please note that this Privacy Policy does not apply to Information that you choose to disclose or submit to:

  1. a) services other than ezsy (such as other products or services supplied or operated by us or our affiliates), that do not expressly state that this Privacy Policy applies;
  2. b) any third party services (including any third party websites) that you may access through ezsy; or
  3. c) companies or organisations that advertise products or services on ezsy.

If you are using ezsy on behalf of a company, partnership, association, government or other organisation (your “Organisation”), you agree to notify your Organisation’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time (“Connected Persons”) of the collection of their Personal Information, and you agree to obtain your Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to “you” or “your” this includes you and any Connected Persons. If you or any Connected Persons would like to request your personal information be removed from our database, please contact us at privacy@ezsy.com.

1.2.2 CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.

Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link and notify you via ezsy or other means before the change becomes effective.

1.2.3 TYPES OF INFORMATION WE PROCESS

We process different categories of information and data in providing ezsy. These are set out below:

  • ”Location Data” is information that is derived from your GPS, WiFi, compass, accelerometer, IP address, or public posts that contain location information. You will disclose certain location information to us and to other ezsy users:
    • when you use certain location-based features, and when you share your location with other ezsy users; and
    • when you access ezsy, as we derive location information from your IP address, device, or internet service to prevent multiple or fraudulent log-ins to your account.
  • “Log Data” is information that we automatically collect when you use ezsy, whether through the use of cookies, web beacons, log files, scripts or ETags including:
    • technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access ezsy, your IP address and your device’s version and identification number;
    • information about what you have searched for and looked at while using ezsy, such as web search terms used, social media profiles visited, and details of other information and content accessed or requested by you in using ezsy;
    • general information about communications on the platform, such as the identity of a user that you have communicated with and the time, data and duration of your communications (but not the content of such communications, except where you are communicating with an Official Account or our support services team); and
    • metadata, which means information related to items you have made available through ezsy, such as the date, time or location that a shared photograph or video was taken or posted.
  • “Non-Personal Information” is any information that is not reasonably practicable to directly or indirectly identify you.
  • “Personal Information” is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you.
  • “Shared Information” is information about you or relating to you that is voluntarily shared by you on ezsy. Shared Information may include postings that you make on ezsy (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using ezsy share about you.

 

References to “Information” in this Privacy Policy mean both Personal Information and Non-Personal Information.

1.2.4 HOW WE PROCESS YOUR INFORMATION

The following lists what Personal Information we collect, how we use it

Information

Purpose of Processing

Registration Data and Log-in Data.Your name, user alias, mobile phone number, password, gender, and IP address.

  • to set up and log-in to a user account on Fincy;
  • to notify you about changes to Fincy;
  • to facilitate communication;
  • to provide you with user support;
  • to enforce our terms, conditions, and policies;
  • to place VoIP calls using Fincy;
  • to communicate with you;
  • to provide personalised help and instructions;
  • to better understand how you access and use Fincy;
  • to develop new and improve existing services;
  • to provide language and location customisation;
  • to protect any rights, property or safety of ours, our affiliate companies, or other users of Fincy; and
  • to administer Fincy and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.

User Profile Search Data.Record of search inquiries.

  • to provide quick access to previous searches.

Shared Information – Profile Data.Any information that you include in your publicly-visible ezsy profile, which may include your profile ID, name, and photo.

  • to administer the ezsy platform in accordance with your instructions and requests;
  • to provide personalised help and instructions;
  • to provide language and location customisation;
  • to develop new and improve existing services;
  • to better understand how you access and use ezsy;
  • to maintain your ezsy account in accordance with your instructions and requests.

Shared Information – Profile Media.This comprises all of the information you make available to other users via ezsy, comprising:

  • ezsy Moments posts and responding to other users’ ezsy Moments; and
  • information made available by another user about you via their use of ezsy – for example, any Shared Information that others using ezsy make available about you via ezsy Moments and communications they make to you and others using ezsy.
  • to administer the ezsy platform;
  • to provide personalised help and instructions;
  • to provide language and location customisation;
  • to develop new and improve existing services;
  • to maintain your ezsy account;
  • to better understand how you access and use ezsy.
  •  

Chat Data.Content of communications between you and another user or group of users. This is stored on your device and the devices of the users that you have sent communications to. We do not permanently store this information on our servers and it only passes through our servers so that it can be distributed to the users you have chosen to send communications to.

  • to facilitate delivery of communication to another user.

Contacts List.Your on-device contact list.

  • to connect you with other ezsy users using the “Recommended Friends” function.

OpenID.We generate an OpenID each instance your ezsy account activates a third-party ezsy Open Platform service. It is a unique identifier that only exists for one account connecting to a single service and allows it to be identified without using other personal information – for example, your name or email address. In addition, we create a UnionID for each instance your ezsy account connects to a service or services operated by a single third-party operator. This allows the third-party operator to associate your activity more easily across various inter-related services offered by the same operator.

  • to allow you to follow an Official Account;
  • to allow you to use a Mini Program; and to allow you to use your ezsy ID to log-in to third party services

Log Data.See definition above.

  • to better understand how you access and use ezsy;
  • to administer ezsy;
  • for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.
  •  

Location Information.See definition above.

Please note the use of products and services that use location information.

  • to provide quick access to previous searches.

User Profile Search Data.Record of search inquiries.

  • account management (such as to ensure there are not multiple log-ins or suspicious log-ins on your account);
  • to provide you with location-based services that you choose to use:
    • oShare Location (when you elect to share your location within a chat with other users):
    • Moments/Point of Interest (geo-tagging a place in a Moments post);
    • WeRun (when you elect to use this feature ezsy uses your accelerometer)
    • Official Accounts (if you elect to disclose your location to an Official Account, that information will be shared with the Official Account);
    • Mini Program (if you choose to disclose your location to a Mini Program, or choose to find Mini Programs Nearby);
    • People Nearby, (location-based services that you can choose to use to disclose your general location for a limited period of time (and you can choose to clear such location data at any time);
    • Top Stories (if you access this feature, we use your location to
    • Optimize locally relevant news content for you);
    • Search (if you perform an external search using ezsy, the service uses your location to provide you with locally relevant information);
  • to provide language and location customisation.

Credit card information.

  • In some regions, credit card information is collected and the card information verified via a third-party payment processing service for the purpose of verifying parental or guardian consent to use ezsy by an underage minor. This information is not permanently stored to ezsy’s servers and is immediately disposed after a verification request has been performed by the third-party payment processing service.

Customer Support Information.Any information that you provide to our customer support team.

  • to investigate your support issue.

Device Data.Media stored on your device.

  • to facilitate the sharing of such media using ezsy.

Social Connect Information.Third Party Social Media e.g. Facebook, QQ (as applicable).

  • If you choose to connect a third party social media account to your ezsy account, we process this information to facilitate login to ezsy via social media account.
  • if you publish content on your Moments, ezsy will facilitate the publishing to a authenticated third party social media account if you choose to share this content to the third party account.

Surveys.If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys and this will be notified to you prior to you completing the survey.

  • to better understand how you access and use ezsy;
  • to provide personalised help and instructions;
  • to develop new and improve existing services;
  • to improve ezsy and respond to customer requests and preferences.

Pseudonymised and Aggregated Data. We pseudonymise and aggregate certain Personal Information to improve our services.

  • Analysis of what features or actions are taken within the app in order to improve app experience
  • Fraud detection and account safety analysis
  • User demographic analysis on items such as region, phone model, operating system platform, system language, and ezsy version in order to better understand how our users are using ezsy
  • Web and account traffic statistics of what content and services are used when users access third-party services on the ezsy Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by ezsy users.

Cookies. We further explain such collection in “Tracking Technologies” section.

  • to facilitate log-in and account verification;
  • to assess effectiveness of and improve advertising and other marketing and promotional activities.

Additional Registration Data – Verified Account.Nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card, home return permit, etc.), personal identification document number, occupation, and source of funds.

If you choose to apply for account verification (in order to unlock additional payment and fund settlement features in ezsy), we use this information to:

  • to verify your identity; and
  • to facilitate payment and funds settlement.

Payments Information.Your credit card number, expiry, CVC and cardholder name. Please note that where a payment is processed by a third party payment service provider, we do not collect or store any Personal Information, though we may receive summary information about transactions.

  • to facilitate your purchases within ezsy; and
  • to validate your Identification.

Personal Information within Your Content

If any of your Personal Information comprises Your Content, we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the ezsy Terms of Service.

1.2.5 SHARING OF YOUR PERSONAL INFORMATION

We will not transfer your Personal Information to any other third parties except as specified below, or in circumstances where you consent to such transfer.

We share your information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:

  • government, public, regulatory, judicial and law enforcement bodies or authorities: where we are required to comply with applicable laws or regulation, a court order, subpoena or other legal process, or otherwise have a legal basis to respond to a request for data from such bodies, and the requesting entity has valid jurisdiction to obtain your personal information;
  • related group companies:we share your Personal Information within our group of companies for the purpose of:
    • providing ezsy to you, assisting us in carrying out the purposes set out under the “How We Collect and Process Your Information” section above, and carrying out our obligations and enforcing our rights under the ezsy Terms of Service or this Privacy Policy; and
    • in the event of an internal restructuring of our or our affiliates businesses, or the sale of ezsy or any of its assets to a third party, the entity that consequently operates ezsy may be a different entity to us and we will transfer your information accordingly so that your service can continue;
  • Third party service providers:service providers supplying services to support, improve, or advertise through our services. These include communication service providers who send SMSs on our behalf, VoIP providers for connection to traditional telephony services card processing and verification, and translation services. We also use service providers to help speed up content delivery to you in your region using acceleration points and content delivery networks; and to provide location and mapping data. Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in this policy.
  • ezsy Official Accounts and Mini Program operators, other services via which you choose to use ezsy Login for third-party apps, if you elect to follow or use the relevant Official Account / Mini Program / ezsy Login for third-parties.

1.2.6 SHARED INFORMATION

ezsy enables certain information to be shared publicly with your ezsy contacts and other users of ezsy. At any time you can hide your profile from public view and search by unchecking “allow find by phone number in your account settings. This means that other users of ezsy will not be able to find you. We refer to this type of information above as Shared Information. Shared Information will remain publicly-available for so long as you or a user that has shared such information retains it. Even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.

Where you have requested that we erase your Personal Information that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Personal Information or providing links to the Personal Information to erase it too.

Please consider carefully what you post and communicate through ezsy.In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in ezsy.

1.2.7 COMMUNICATIONS FROM US

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend ezsy for maintenance, or security, privacy, or administrative-related communications). We communicate these via website announcement, in-app announcement. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes ezsy.

1.2.8 SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to ezsy, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

Before communicating any Personal Information of a sensitive nature within ezsy, please consider whether it is appropriate to do so.

By posting any Personal Information of a sensitive nature within ezsy, you are consenting to such information being available within the controls you have selected (for example, available to the audience of users you select as being capable of viewing your post or profile information).

1.2.9 SOCIAL MEDIA SHARING

Sharing Your ezsy Data outside of ezsy

We provide other ezsy-related features that allow you to disclose Shared Information to audiences outside of your ezsy network – for example, publicly accessible blogs and forums, or certain social media features within ezsy (such as “plug-ins” (which create a direct link between two websites) and “widgets” (which are interactive Mini Programs that provide third party services within ezsy)) allow you to re-post and disclosure Shared Information. Any information you distribute using such features may be read, collected, and used by third parties that are not controlled by ezsy.

You may link your ezsy contact list to your contact lists on your device and/or in your account on third party services, in order to search for and connect with contacts on those contact lists who also have a ezsy account. ezsy will ask you to consent to accessing your contact list before doing so.

Accessing and Importing Information using ezsy

ezsy allows you to link your ezsy services with select third party social media services, and import certain content and information from such third party services. For example:

  • you may share content on, or login to, ezsy using services provided by third parties. These third party services will authenticate your identity and provide you with the option of sharing certain Personal Information with us. They may also give you the option to post information from your third party service account to ezsy as Shared Information.
  • you may login to ezsy using other sign-in services such as an Open ID provider. These sign-in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and
  • ezsy may (whether in advertisements or otherwise within ezsy) provide you with links or features that allow you to access third party services or websites (or access within ezsy content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party without leaving the ezsy application.

Third party social media platforms are hosted by the relevant third party. ezsy services are hosted by us. Third parties that provide third party services may collect your Information (including your Personal Information and Log Data), and set cookies on your computer, or device to enable such features to function properly.

Your use of any third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party’s own terms of services and privacy policies and not the ezsy Terms of Service or this Privacy Policy, so please review those third party terms carefully.

This Privacy Policy only applies to any Information collected by us, and does not apply to any services offered by or information practices of any third parties. If you choose to use third party services or features that are made available within ezsy (for example, you choose to follow an Official Account or use a Mini Program), then we will share certain information with that third party to allow you to use that third party service. The information we share with such a third party is described to you at the time you first use that service or feature, and that third party will provide the same or equal protection of user data as stated in the this policy. You can control which third parties have access to this information in your account. Please note however that if you ask us not to share that information with the third party, you may no longer be able to use that service or feature. We are not responsible for any third party use of any Information provided by you to them.

1.2.10 AGE RESTRICTIONS

ezsy is not intended for Children. Children under the age of 16 must not use ezsy for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect Personal Information from any children under the age of 16 without such consent. Please contact our Data Protection Officer if you believe we have any Personal Information from any children under the age of 16 without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.

1.2.11 LOCATION OF YOUR PERSONAL INFORMATION

The Personal Information that we collect from you will be transferred to, stored at, or processed in Singapore or Hong Kong. Our engineering, technical support, and other teams that support the supply of ezsy to you are based in our offices around the world and may have incidental access to certain of your data in order to provide the service (for example, in order to fix technical issues that you report).

SECURITY OF YOUR PERSONAL INFORMATION

We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access, or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us.

Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of ezsy or any information you provide to us through ezsy.

1.2.12 YOUR RIGHTS

Access & Correction

Upon request ezsy will provide you with information about whether we hold any of your personal information. You also have the right to access personal information we hold about you, how we use it, and who we share it with. You also have the right to correct that information.

You can access and correct your personal information by logging into your ezsy account at any time. For example, you can delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within ezsy.

We may not be able to provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person).

With respect to correction requests, where we agree that the Personal Information is inaccurate or incomplete, we will try to tell any third party to whom we have disclosed the relevant Personal Information so that they can rectify the Personal Information too.

Erasure

You can delete your account, or remove certain personal information, by logging into your ezsy account and following the account deletion instructions. You may request that we erase the Personal Information we hold about you in the following circumstances:

  • you believe that it is no longer necessary for us to have your Personal Information;
  • we obtained your consent to process the Personal Information and you withdraw that consent (and we have no other grounds for processing the Personal Information);
  • you believe we are unlawfully processing your Personal Information; or
  • you are or were under the age of 13 when we collected the Personal Information and we can verify your age.

Also note that you may exercise your right to restrict our processing of your Personal Information (as described below) whilst we consider a request to erase your data.

Please note, however, that we may retain the Personal Information if there are valid grounds under law for us to do so (e.g., for the defence of legal claims, freedom of expression or some other legal obligation) but we will let you know if that is the case.

Where you have requested that we erase your Personal Information that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Personal Information or providing links to the Personal Information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the Personal Information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Information, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

Where we agree to stop processing the Personal Information, we will try to tell any third party to whom we have disclosed the relevant Personal Information so that they can stop processing it too.

You may request we stop processing and just store the Personal Information we hold about you where:

you believe the Personal Information is not accurate (for the period it takes for us to verify whether it is accurate);

we wish to erase the Personal Information as the processing we are doing is unlawful (but you want us to retain the Personal Information and just store it instead); or

we wish to erase the Personal Information as it is no longer necessary for our purposes (but you require it to be stored for the establishment, exercise or defence of legal claims).

Portability

You have the right to receive a copy of certain Personal Information we collect from you. This comprises any personal information we process on the basis of your consent (e.g., voluntarily-provided profile data, social media content posted to Moments, content selected to store to Favourites) or pursuant to our contract with you (e.g., profile data). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer the Personal Information to a third party, please ensure you detail that party. Note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Information or its processing once received by the third party. We also may not provide you with certain Personal Information if providing it would interfere with another’s rights (e.g. where providing the Personal Information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Objection

You may object to our use of your Personal Information if we use your information on the basis of our legitimate interests (such as when we use your personal information for your account security, such as to prevent malicious log-ins).

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us.