1. Introduction
This policy outlines how Ezgage (“Ezgage,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal data when you use our services and access our platform. We are committed to safeguarding your privacy and ensuring the security of your personal data in compliance with applicable laws, including the General Data Protection Regulation (GDPR).
2. Information We Collect
2.1. Personal Data:
Personal data refers to any information relating to an identified or identifiable individual. This includes:
- Identification Data: Name, email address, country, postal address, phone number, and other identifiers;
- Profile Information: Public data from social media network(s) profile(s), including username(s), content and other related data;
- Financial Information: Payment information, transaction history, and billing details;
- Verification Data: Identity verification documents and details required for compliance with legal obligations.
2.2. Technical Data:
Technical data includes:
- Device Information: Information about the devices you use to access our services, such as IP address, browser type, and operating system;
- Usage Data: Information about how you use our services, including the pages you visit, the links you click, and the time you spend on our platform.
2.3. Interaction Data:
Interaction data includes:
- Engagement Metrics: Public data on interactions with campaigns, likes, shares, comments, and other engagement activities on social media network(s);
- Points and Rewards: Information on points earned, redeemed, and transaction history within the Ezgage ecosystem.
2.4. Third-Party Data:
We may collect data from third parties, such as:
- Social Media Network(s): Public data from social media profiles and respective activity;
- Partners and Affiliates: Information from our business partners and affiliates that help us provide our services.
2.5. App Permissions:
Such as:
- Photo Library Access: To personalize your account, we require access to your photo gallery. This access will allow you to select photos and videos from your library to update your profile or attach files for support. We will only access your gallery for these specific purposes and will not access your photos or videos for any other reason or at any other time;
- Camera Access: To personalize your account, we require access to your camera. to update your profile or attach files to support. You can use the camera to take photos and videos directly within the app or login via Face ID. We will not access your camera for any other reason or at any other time;
3. How We Use Your Information
3.1. Service Provision
- Account Management: To create and manage your Ezgage account;
- Campaign Management: To enable you to create, manage, and track social media campaigns;
- Payment Processing: To process transactions and manage billing.
3.2. Service Improvement
- Analytics: To analyze how our services are used and to improve their functionality and performance;
- User Feedback: To gather feedback to improve our services and develop new features.
3.3. Legal and Compliance
- Verification: To verify your identity and comply with legal and regulatory obligations, such as anti-money laundering (AML) and counter-terrorism financing (CTF) laws, when applicable;
- Fraud Prevention: To detect and prevent fraud, abuse, and other harmful activities.
3.4. Marketing and Communications
- Promotions: To send you marketing communications, promotional offers, and other information that may be of interest to you;
- Notifications: To communicate with you about your account, transactions, and updates to our services.
4. Sharing Your Information
We do not sell your personal data to third parties. However, we may share your information with:
- Service Providers: Third-party service providers that perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, and customer support;
- Affiliates: Our affiliates for purposes consistent with this privacy policy.
- Legal Obligations: Regulatory authorities, law enforcement agencies, and other parties to comply with legal obligations or to protect the rights, property, or safety of Ezgage, our users, or others;
- Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
5. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption, access controls, and secure data storage facilities.
7. Your Rights
Under the GDPR, you have the following rights:
- Access: You have the right to request access to your personal data and to receive a copy of the information we hold about you;
- Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
- Erasure: You have the right to request the deletion of your personal data under certain conditions;
- Restriction: You have the right to request the restriction of processing your personal data under certain conditions;
- Objection: You have the right to object to the processing of your personal data under certain conditions;
- Withdrawal of Consent: Where you have provided consent to the processing of your personal data, you have the right to withdraw your consent at any time.
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect and use personal data about you, including to serve interest-based advertising. You can manage your cookie preferences through your browser settings.
9. International Transfers
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We take appropriate safeguards to ensure that your personal data remains protected in accordance with this privacy policy.
10. Children’s Privacy
Our services are not intended for individuals under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that a child under 13 has provided us with personal data, we will take steps to delete such information.
11. Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new privacy policy on our platform and updating the “Last Update” date at the top of this policy.
12. Contact Us
If you have any questions or concerns about this privacy policy or our data practices, please contact us at:
- Ezgage Support: Email: [email protected]
13. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy policy. If you have any questions about this privacy policy or our data protection practices, please contact our DPO at:
- Data Protection Officer: Email: [email protected]
14. Data Processing Principles
We adhere to the following data processing principles:
- Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly, and in a transparent manner;
- Purpose Limitation: We collect personal data for specified, explicit, and legitimate purposes and do not process it further in a manner that is incompatible with those purposes;
- Data Minimization: We ensure that personal data is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
- Accuracy: We take reasonable steps to ensure that personal data is accurate and, where necessary, kept up to date;
- Storage Limitation: We keep personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed;
- Integrity and Confidentiality: We process personal data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
15. Legal Bases for Processing Personal Data
We process your personal data based on the following legal bases:
- Contractual Necessity: To perform a contract with you or to take steps at your request before entering into a contract;
- Legal Obligation: To comply with a legal obligation;
- Legitimate Interests: To pursue our legitimate interests, provided that such interests are not overridden by your rights and interests;
- Consent: Where you have provided consent to the processing of your personal data.
16. Automated Decision-Making
We do not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you, unless you have given explicit consent, it is necessary for entering into or performing a contract, or it is authorized by applicable law.
17. Third-Party Links
Our platform may contain links to third-party websites. This privacy policy does not apply to those websites, and we are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit.
18. Data Subject Rights in Portugal
As Ezgage is based in Portugal, we comply with the Portuguese Data Protection Law (Lei de Proteção de Dados Pessoais). In addition to the rights outlined above, you have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados – CNPD) if you believe that your data protection rights have been violated.
Comissão Nacional de Proteção de Dados (CNPD):
- Website: https://www.cnpd.pt/
19. Changes to Your Information
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can update your information through your account on our platform or by contacting our support team.
20. Data Breach Notification
In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. We will also take appropriate measures to mitigate the breach and prevent future incidents.
21. International Data Transfers
We may transfer your personal data to countries outside the European Economic Area (EEA). When we do so, we ensure that your personal data is protected by appropriate safeguards, such as standard contractual clauses approved by the European Commission, binding corporate rules, or other legally recognized means.
22. Data Protection Impact Assessments
We conduct Data Protection Impact Assessments (DPIAs) when processing activities are likely to result in a high risk to the rights and freedoms of individuals. DPIAs help us identify and mitigate potential privacy risks associated with our data processing activities.
23. Training and Awareness
We provide regular training to our employees on data protection principles and practices to ensure that they understand their responsibilities and handle personal data in accordance with this privacy policy and applicable laws.
24. Public Data from Social Media Networks
Ezgage collects and processes publicly accessible data from social media networks to provide our services. This includes, but is not limited to, the following types of data:
- Public Posts and Content: Information that users share publicly on their social media profiles, such as text posts, photos, videos, and other multimedia content;
- Engagement Metrics: Data related to user interactions, such as likes, comments, shares, retweets, and other forms of engagement with posts;
- Profile Information: Publicly visible information on user profiles, such as username, bio, profile picture, follower and following counts, and any other information that the user has made publicly available;
- Social Network Activity: Information about the user’s activities on social media networks, including the frequency and type of posts, engagement with other users, and participation in public discussions and groups.
24.1. No Collection of Credentials:
Ezgage emphasizes that we will never request, collect, or store any login credentials or passwords from users. Our data collection methods are designed to respect user privacy and adhere to the terms of service of the social media networks from which the data is sourced.
24.2. How We Use Public Data:
The public data we collect from social media networks is used for the following purposes:
- Profile Addition: To add social media profiles to the Ezgage platform, enabling users to manage their social media presence within our ecosystem;
- Campaign Creation and Management: To enable users to create and manage social media campaigns, and to track the performance of these campaigns based on public engagement metrics;
- Analytics and Insights: To provide users with detailed analytics and insights into their social media presence, helping them understand trends, audience engagement, and overall performance;
- Monetization: To facilitate the monetization of social media activities by allowing users to earn points and rewards based on their public interactions and engagement metrics;
- Content Quality and Compliance: To ensure the quality and compliance of content within the Ezgage ecosystem, and to prevent the spread of harmful or inappropriate content.
24.3. How We Use Public Data:
Our processing of publicly accessible data from social media networks is based on the following legal bases:
- Legitimate Interests:
We process public data to pursue our legitimate interests in providing and improving our services, as long as these interests are not overridden by the rights and interests of the data subjects; - Contractual Necessity:
In some cases, processing public data is necessary to fulfill our contractual obligations to users who have signed up for our services.
24.4. Data Minimization and Accuracy
We adhere to the principles of data minimization and accuracy in our data processing activities. This means we only collect data that is necessary for the purposes outlined in this policy, and we take reasonable steps to ensure the data we collect is accurate and up-to-date.
24.5. User Control and Transparency
We believe in providing users with control and transparency over their data. Users can manage their social media profiles connected to Ezgage and control the data we collect and process.
24.6. Security Measures
We implement robust security measures to protect the public data we collect from social media networks. These measures include encryption and access controls.
25. Accountability
We are responsible for ensuring compliance with this privacy policy and applicable data protection laws. We maintain records of our data processing activities and regularly review and update our data protection practices to ensure ongoing compliance.
Thank you for trusting Ezgage with your personal data. We are committed to protecting your privacy and ensuring the security of your information. If you have any questions or concerns about this privacy policy or our data protection practices, please do not hesitate to contact us.
Ezgage Support
- Email: [email protected]
Data Protection Officer
- Email: [email protected]
Table of Contents
- 1. Introduction
- 2. Information We Collect
- 3. How We Use Your Information
- 4. Sharing Your Information
- 5. Data Retention
- 6. Security
- 7. Your Rights
- 8. Cookies and Tracking Technologies
- 9. International Transfers
- 10. Children’s Privacy
- 11. Changes to This Privacy Policy
- 12. Contact Us
- 13. Data Protection Officer
- 14. Data Processing Principles
- 15. Legal Bases for Processing Personal Data
- 16. Automated Decision-Making
- 17. Third-Party Links
- 18. Data Subject Rights in Portugal
- 19. Changes to Your Information
- 20. Data Breach Notification
- 21. International Data Transfers
- 22. Data Protection Impact Assessments
- 23. Training and Awareness
- 24. Public Data from Social Media Networks
- 25. Accountability