Zenova Privacy Policy
**ZENOVA Basic Function Privacy Policy**
**Version Update Date:** February 21, 2025
**Effective Date:** February 28, 2025
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**Special Notice**
This Policy applies exclusively to products, services, and extended functionalities provided by ZENOVA Limited and its affiliates, including the ZENOVA App, websites, clients, mini-programs, and new forms of products/services developed with technological advancements. If a specific product has a standalone privacy policy or special terms in its user agreement, that product’s privacy policy shall take precedence. Matters not covered by such policies shall be governed by this Policy. For products/services offered by ZENOVA’s affiliates that utilize ZENOVA’s services without a standalone privacy policy, this Policy shall apply.
Please read the **ZENOVA Basic Function Privacy Policy** (especially bolded sections) to understand how we process your personal information. If you have questions, contact us via the methods provided in this Policy.
**For Users in the EU, EEA, UK, or Switzerland:** Before submitting orders or modifying addresses when purchasing ZENOVA goods/services, please review the **"Europe-Specific Policy"** in detail.
The ZENOVA App is an e-commerce platform. By agreeing to this Policy, you acknowledge and consent to our collection and processing of necessary personal information for online shopping functionalities. This does not imply consent for non-essential personal data collection.
**Contact Us:**
- Email: [email protected]
- Registered Address: Room 222, 2nd Floor, Building C, No. 18 Ke Chuang 11th Street, Shenzhen Economic and Technological Development Zone
- Office Address: No. 18 Ke Chuang 11th Street, Shenzhen Economic and Technological Development Zone
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**Introduction**
Welcome to ZENOVA! We prioritize user privacy and personal information protection. This Policy explains how we collect, use, store, share, transfer, and protect your information when you use our products/services.
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**Table of Contents**
1. How We Collect and Use Your Personal Information
2. Use of Cookies and Similar Technologies
3. How We Share Your Personal Information
4. How We Protect and Store Your Personal Information
5. Managing Your Personal Information
6. Protection of Minors’ Personal Information
7. Notifications and Updates
8. Contact Us
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**1. How We Collect and Use Your Personal Information**
To provide e-commerce services, we collect **necessary personal information** (e.g., phone number, recipient name, address, payment details). Bolded fields in this Policy specify critical data. Without such information, core functionalities may be unavailable.
**Additional Features:**
- Permission-based shopping experiences and public content posting require separate consent. Denial affects only these features.
**Key Scenarios:**
**(1) Account Registration/Login**
- Required: Mobile number (via SMS verification). Optional: Nickname, profile picture, real-name authentication.
- Third-party login (e.g., social media) requires authorization.
**(2) Product/Service Display**
- Device info (model, OAID/IDFA, OS), location (with consent), browsing/search history, and order data are used for personalized recommendations.
- Opt-out options for ads/promotions:
- Long-press recommended items to block categories.
- Adjust search filters (price, sales).
- Unsubscribe from SMS/email promotions.
- Manage ad preferences via "My Account > Privacy Settings."
**(3) Order Management**
- **Order Information:** Recipient details, address, contact info, payment method. Used for delivery, customer service, and fraud detection.
**(4) Payment**
- Third-party payment providers (e.g., WeChat Pay, UnionPay) process transactions under their privacy policies.
**(5) Delivery**
- ZENOVA, affiliates, or logistics partners use order info for secure delivery.
**(6) Customer Service**
- Verify identity via account/order info. Collect return addresses for refunds.
**(7) Security**
- Device data, IP, logs, and SIM info are used to prevent fraud and ensure system stability.
**(8) Additional Features**
- App permissions (e.g., camera, location) enhance shopping experiences. Manage via "Privacy Settings."
- Public posts (reviews, Q&A) may include personal info—obtain others’ consent before sharing.
**(9) Other Uses**
- Anonymized data for analytics.
- New purposes require explicit consent.
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**2. Use of Cookies and Similar Technologies**
- **Cookies:** Store login status, preferences, and security tokens. Adjust browser settings to block/delete.
- **Web Beacons:** Track page visits and user interactions.
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**3. Sharing Your Personal Information**
We share data only under these circumstances:
1. With your explicit consent.
2. To comply with legal obligations.
3. To resolve disputes or enforce agreements.
4. For public health/safety emergencies.
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**4. Protection and Storage**
- **Security Measures:** Encryption (HTTPS, SHA256), access controls, audits, and staff training.
- **Retention Period:** Retained per legal requirements (e.g., 3 years under China’s E-Commerce Law). Cross-border transfers require your authorization.
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**5. Managing Your Information**
- **Access/Correct:** Update account, address, or order details via "My Account" settings.
- **Delete:** Remove browsing history, comments, or invoices. Submit requests via email.
- **Withdraw Consent:** Adjust permissions in "Authorization Management."
- **Account Deletion:** Follow steps in **ZENOVA Account Deletion Guidelines**.
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**6. Minors’ Privacy**
- Users under 18 require parental consent.
- Special protections for children under 14:
- Designated team and邮箱: [email protected].
- Parents may submit correction/deletion requests.
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**7. Updates**
- Significant changes (e.g., data usage purposes, ownership transfers) will be notified via email, SMS, or in-app alerts.
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**8. Contact Us**
- Privacy Officer: [email protected]
- Complaints may be escalated to regulatory authorities.
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**Note:** Ensure email domains (e.g., giftborad.com) and addresses are validated for accuracy. Cross-check version dates (update vs. effective) for consistency.
Zenova Privacy Policy for Europe Region
Dear ZENOVA users:
ZENOVA is committed to protecting the privacy and personal data of its users. If you are purchasing goods or services (the "Services") from ZENOVA in the European Union (EU), the European Economic Area (EEA), the United Kingdom or Switzerland, please read this policy (this "Europe Region Policy") carefully before [submitting orders, modifying and adding an address] to make sure you understand our rules for processing your personal data. By clicking on "Acknowledge" on the website or otherwise submitting your information, you acknowledge that you fully understand and agree to this Europe Region Policy.
This Europe Region Policy is an important supplement to ZENOVA Privacy Policy for Basic Services ( "ZENOVA Privacy Policy"). For personal data processing rules that are not covered in this Europe Region Policy, ZENOVA Privacy Policy shall prevail.
For the purposes of this Europe Region Policy, the data controller of your personal data is [Shenzhen Zenova E-Commerce Co., Ltd..] (hereinafter "ZENOVA", "we" or "us").
If you have any questions, comments or suggestions, you may contact us by the following means:
Email: [email protected]
Registered Address: Room 222, 2/F, Block C, No. 18, Kechuang 11th Street, Shenzhen Economic and Technological Development Zone, Shenzhen, P.R. China
Office Address: No. 18, Kechuang 11th Street, Shenzhen Economic and Technological Development Zone, Shenzhen, P.R. China
A. Types of Personal Data Processed and Processing Purposes and Methods
We may process the following personal data about you for the following purpose:
- Account registration and login:
Your basic personal data, including your account number, password, mobile number, nickname;
- Order placement and management, payment and delivery:
Your purchase information, including the goods you purchased, time of order placement, payment information, order number, tracking number, shipping address, recipient's name, phone number, email address, gender and birthday, your identity information, including your identity document number, name, etc.
- Customer and after-sales services
Your after-sales information, including your account information, order information, contact details, and information about your return of goods; and/or
- Display of product/service information and ensure transaction security
Information about the device you use to interact with us, the browser type, log information, your browsing history, etc.
We will collect your personal data in the following ways:
- We collect personal data about you in direct connection with the Services. For example, we collect your personal data when you browse our websites, log into your account, or purchase a product, or when you communicate with us via email, telephone, text message, or by any other electronic means.
- We also collect your personal data from your devices automatically. We use cookies and other tracking tools and technology that will send one or more small data files called cookies to your web browser or mobile device to collect information about your general Internet usage.
- We also collect your personal data from the following sources, including:
o Social media services - from which we may collect information such as your username, profile picture, and email address associated with the relevant third-party service provider, if you choose to register or log in on the Service using said third-party service.
o Logistics service providers - to effectively complete order fulfilment, we will obtain your logistics information from logistics providers, such as delivery progress and delivery address.
For more details, please see ZENOVA Privacy Policy.
B. Lawful Bases for Processing Your Personal Data
The lawful bases vary depending on the specific use of the personal data by ZENOVA. ZENOVA's legal bases for processing your personal data may include:
- Performance of Contracts. ZENOVA may process your personal data when providing services or communicating with you about services, including creating or maintaining your account, processing your orders and payments, and providing after-sales services.
- Legitimate Interests. However, we will refrain from using your personal data if, after careful consideration, we believe that our use of your personal data will harm your interests or your fundamental rights and freedoms associated with your personal data. We may use your personal data to, for example, improve ZENOVA services, e.g. optimize functionality, analyse performance, fix bugs; marketing communications; and detect and prevent fraud to protect the safety of ZENOVA's customers, ZENOVA itself or others, and when we recommend features, products, and services that may be of interest to you, also to determine your preferences and personalise your experience with the Service.
- Your Consent. We will seek your consent when we process your personal data for a specific purpose you will be informed of. If you have given us your consent to processing your personal data for a particular purpose, you may withdraw your consent at any time and we will no longer process your personal data for that purpose.
- Compliance with Legal Obligations. ZENOVA may use your personal data to comply with applicable laws, regulations, lawful requests, or legal proceedings (e.g., to respond to requests from government authorities); to protect your rights, privacy, safety, or property and the rights, privacy, safety, or property of ZENOVA and other users (including to make or defend claims); or to prevent, identify, investigate and stop fraudulent, unauthorised, unethical or illegal activities, including cyber-attacks and identity theft.
C. Sharing with Third Parties
For the purposes above, we may share your personal data with third parties in the following circumstances:
- When you use the Services in the European Union (EU), the European Economic Area (EEA), the United Kingdom or Switzerland, we need to provide the following information to [JCEX International Logistics Co., Ltd.] (a company located in Hangzhou, Zhejiang Province, China) for the delivery of the goods or services purchased by you: your order number, tracking number, shipping address, phone number, post code, email address, and contact person, after such information has been [encrypted]. Logistics Service Provider undertakes that it will comply with applicable laws and regulations in processing such information and take proper security measures to protect your personal data;
- [We may provide your personal data to our contractors, vendors, or service providers to perform functions on our behalf, including but not limited to providers of IT maintenance, trunk transportation, customs clearance, and delivery. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.
- We may provide your personal data to government or regulatory authorities (such as tax authorities), and courts where we believe this is necessary to comply with a legal or regulatory obligation.]
D. Cross-border Transfer of Your Personal Data
ZENOVA is based in China, and your personal data is mainly stored and processed in China. ZENOVA may transfer your data outside of the European Union (EU), the European Economic Area (EEA), the United Kingdom or Switzerland for processing, including in countries where data protection and privacy laws or regulations may not be equivalent to, or as protective as, the data protection and privacy laws and regulations in Europe.
In accordance with applicable laws, we will implement appropriate measures to ensure that your personal data remains fully protected when it is transferred to a jurisdiction outside of Europe, including transferring personal data pursuant to standard contractual clauses (often called “SCCs”).
For more information about the cross-border transfer of your personal data, please contact us by means specified in this Europe Region Policy.
E. Data Security and Retention
ZENOVA takes the security of your personal data very seriously. We use technical and administrative measures to help protect your personal data from loss, theft, misuse, unauthorized access, disclosure, alteration and/or destruction. However, security risks are inherent in all forms of Internet and information technology.
In general, we retain personal data to fulfil the purposes for which we collect it, to comply with any legal, accounting or reporting requirements, to make or defend claims, or to prevent fraud. In determining the appropriate retention period for personal data, we may take into account the following factors: the purposes for which we process your personal data; whether we can achieve those purposes by other means; and applicable legal requirements. We delete or anonymize the personal data we have collected about you when we no longer need it.
F. Your Data Subject Rights
To the extent our processing of your personal data is subject to any applicable laws, you have the following rights with respect to your personal data:
- Right to Access. You have the right to ask ZENOVA for copies of your personal data.
- Right to Rectification. You have the right to ask ZENOVA to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to Erasure. You have the right to ask ZENOVA to erase your personal data in certain circumstances.
- Right to Restrict Processing. You have the right to ask ZENOVA to restrict the processing of your personal data in certain circumstances.
- Right to Object to Processing. You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal data, which is carried out on the basis of our legitimate interests.
- Right to Data Portability. You have the right to ask that we transfer the personal data you gave us from one organization to another, or give it to you in a structured, ordinarily used, and readable format.
- Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your personal data (ZENOVA processes your personal data based on your consent).
- Right to Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority.
To exercise your rights, you may send a request to [email protected], visit https://help.ZENOVA.com for online customer service, or call our customer service department. We will respond to your request to the extent required by applicable data protection laws.
G. Protection of Children’s Personal Data
Our service is not directed towards children under 18 years old, we do not intentionally or knowingly collect personal data from children.
If you are below 18 years old, you must ask your parents or guardian to read this Europe Region Policy, and use our Services or provide us with your information with prior express consent from your parents or guardian. If your guardian disagrees to your use of our Services in accordance with this Europe Region Policy, please cease immediately the use of our Services and notify us promptly so that we can take appropriate actions.
H. Changes to this Europe Region Policy
We reserve the right to amend this Europe Region Policy. If we make any material changes to this Europe Region Policy, we will notify you by updating the date of this Europe Region Policy, and/or giving notice on our service platform as required by applicable laws. Any changes to this Europe Region Policy will take effect upon the publication of its amended version (or otherwise at the time then specified).
[28] March 2023