Ginzabe’s Privacy Policy

Ginzabe and its subsidiary companies and affiliates are committed to and have a long-standing policy of maintaining the privacy and security of your personal information which is information about an identifiable individual.

This Privacy Policy explains Ginzabe’s practices with respect to the processing of your personal information which includes collection, use, processing, transfer, storage or disclosure of your personal information, except where a Ginzabe subsidiary or affiliate has published its own separate privacy policy. In addition, agreements or notices associated with a particular Ginzabe, service, application, software or website (“Ginzabe Offering”) may provide additional information about Ginzabe’s processing of your personal information (“Notice”). The application of this Privacy Policy remains subject to applicable laws including legislation, regulations and the orders of any courts or other lawful authorities, other lawful requests or legal processes. Where applicable, the data controller in respect of your personal information is the Ginzabe entity with whom you have entered into an agreement.

  1. Ginzabe’s Accountability

Ginzabe is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on Ginzabe’s behalf.

  1. Ginzabe’s purposes for using your personal information

When you use a Ginzabe Offering, correspond with Ginzabe, enter a contest sponsored by Ginzabe or otherwise interact with Ginzabe, Ginzabe may process your personal information for the following purposes:

  • For purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of Ginzabe Offerings.
  • To ensure Ginzabe Offerings are technically functioning as intended and to help identify and troubleshoot issues.
  • To fulfill or enforce Notices applicable to a Ginzabe Offering.
  • To manage or respond to your inquiries.
  • To make available or send to you, upgrades or updates, or notices of upgrades or updates of Ginzabe Offerings or third-party content or related products, services and software; and notices of promotions and upcoming events;
  • To detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect Ginzabe property.
  • To allow for business continuity and disaster recovery operations.
  • To enforce Ginzabe’s legal rights.
  • For statistical purposes.
  • To respond to court orders, warrants or other lawful requests or legal processes.
  • To provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
  • For any other purposes for which you have consented, such as those that may be set out in the Notices, and other purposes as permitted or required by any applicable law.
  1. Your consent

Before using Ginzabe Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding Ginzabe’s processing of your personal information. Your agreement to the Notice or use of Ginzabe Offerings indicates your consent for Ginzabe to process your personal information for Ginzabe’s identified purposes.

a) When obtaining consent is not required

In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For instance, to which, Ginzabe may not seek consent:

  • In the case of an emergency where the life, health or security of an individual may be threatened.
  • When legal or security reasons make it impossible or impractical to seek consent.
  • When information is necessary for the detection and prevention of fraud.
  • When disclosure is to a lawyer representing Ginzabe.
  • To collect a debt.
  • To comply with a subpoena, warrant or other court order, lawful request or legal process; or as may be otherwise required or permitted by law.

b) Aggregated or anonymous information

Ginzabe reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.

  1. Types of information processed

The types of information that Ginzabe may process can vary. For example:

a) Account and membership information: Information processed could include your name, your company name, postal address, email address, telephone number, device identifier information such as your communications with Ginzabe and any recorded complaints. Ginzabe may also process your account credentials, passwords, profile information and other information you provide to facilitate the Ginzabe Offerings you use.

b) Applications: In some cases, Ginzabe may process information about applications used on your device including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with Ginzabe Offerings, but are not offered, operated or supported by Ginzabe). Also, if you choose to use Third Party Offerings with your Ginzabe account or device, certain information may be collected and disclosed to the third party, or from the third party to Ginzabe, to facilitate or improve the services and functionality provided.

c) Cloud-based or back-up data: If you use a cloud-based or back-up and restore service provided by or on behalf of Ginzabe, information from your device or account including contacts, email addresses, calendar, memo, tasks, display pictures, status messages, media files and other on-device information may be sent to Ginzabe in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.

d) Financial information: If you purchase a product, service, software directly from Ginzabe or our service providers, Ginzabe may process receipts or other payment information and use it to facilitate billing services.

e) General usage data: In some cases, information like technical properties and general usage information of software and hardware utilized in conjunction with a Ginzabe Offering might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a Ginzabe troubleshooting tool (e.g. basic usage statistics or information about your device including event logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).

f) Quality assurance and customer service: Your customer service telephone calls with Ginzabe and Ginzabe’s service providers may be recorded or monitored for quality assurance and customer service purposes such as assisting in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to Ginzabe Offerings.

g) Third party information: If necessary to fulfill Ginzabe’s identified purposes, Ginzabe may combine the information you submit to Ginzabe with information obtained from other sources or Third-Party Offerings. Ginzabe treats all such personal information in accordance with this Privacy Policy and the terms and conditions between Ginzabe and such third parties, if any, may also apply. However, the third party’s own use of your personal information in such cases will be determined by your agreement(s) with the third party, unless that third party is a Ginzabe service provider. Some of this information would not by itself identify you to Ginzabe or be personally identifiable and is therefore considered non-personal information. If Ginzabe combines any such non-personal information with other personal information available to Ginzabe, the combined information will be treated as personal information in accordance with this Privacy Policy.

  1. Ginzabe’s processing of your personal information

a) Retention

Ginzabe retains personal information as long as necessary for the fulfillment of Ginzabe’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for Ginzabe’s identified purposes, or required by applicable laws, Ginzabe will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, Ginzabe continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.

b)   International operations and onward transfers

Ginzabe has an international presence, with offices and facilities in multiple jurisdictions. Except where a Ginzabe subsidiary or affiliate has its own separate privacy policy, all Ginzabe’s international operations and onward transfers are subject to this Privacy Policy.

c) Marketing communications from Ginzabe

Ginzabe may communicate with you by a variety of means, such as using the email address(es) that you associate with your Ginzabe device or your unique device identifier (e.g. PIN). Ginzabe may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with Ginzabe. Ginzabe may ask you from time to time if you would like to receive from Ginzabe or authorized third parties selected by Ginzabe additional announcements, news, offers or event invitations regarding Ginzabe and Ginzabe Offerings. You may also choose to provide Ginzabe with information in response to various Ginzabe promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that Ginzabe sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives to obtain further details about how your personal information will be managed. Typically, an unsubscribe mechanism is included with every Ginzabe marketing or commercial communication.

d) Service-related communications from Ginzabe

Ginzabe may also send you certain service-related communications. For example, Ginzabe may send a welcome email or message when you first register your device to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, to provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of Ginzabe Offerings, you may not opt-out of receiving these communications.

e) Information sharing

In accordance with this Privacy Policy, Ginzabe may share your personal information within Ginzabe or with our service providers. Ginzabe may also share information with our financial, insurance, legal, accounting or other advisors that provide professional services to Ginzabe. Ginzabe may also share information in a manner consistent with this Privacy Policy with third parties involved in providing Ginzabe Offerings to you including payment processors, subcontractors or entities participating in Ginzabe’s activates.

In certain situations where you purchase or use a Third-Party Offering, Ginzabe may share certain information with the third party for purposes of providing you with the product, service or software and your information will then be subject to the third party’s privacy policy. We encourage all our users to learn about the privacy practices of such third parties before agreeing to purchase or obtain their products, services or software.

Ginzabe uses contractual or other means to provide a comparable level of protection while the information is being processed by our service providers. It is Ginzabe’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from Ginzabe. Except where Ginzabe is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the information in confidence and only use the information for the purposes for which it was provided or to comply with applicable laws.

In the event of the sale of all or a portion of Ginzabe’s assets, Ginzabe may provide personal information to the third-party purchaser.

  1. Accuracy of your personal information

Ginzabe takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up to date. Ginzabe also depends on you to update or correct your personal information whenever necessary.

  1. Safeguarding your personal information

Ginzabe continues to evolve our physical, organizational and technological measures used to protect your personal information against loss or theft, unauthorized access, alteration or disclosure appropriate to its level of sensitivity. For example, if a Ginzabe website requests your name and password, it will have a variety of security measures in place that are designed to protect against the loss, misuse and unauthorized alteration of the personal information submitted to Ginzabe. Through Ginzabe’s Code of Business Standards and Principles, Ginzabe employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, and to limit access to personal information to those with a need to know it for business reasons.

a) Your obligations to safeguard your personal information

You also have an obligation to safeguard your personal information. You can reduce the risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others, using different passwords for different services and using up-to-date antivirus software.

As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.

If you return, sell, discard, or transfer your device to another person or entity (such as providing your device to another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped off any personal information or other sensitive data they might contain. You should also disassociate your device with all email accounts and other data services so that email and data are no longer directed to the device (e.g. push services, emails delivered through the Ginzabe Internet Service, remote backup). Otherwise, your personal information may be available to a subsequent user of the device, and you may incur subscription charges.

  1. Ginzabe’s ongoing efforts to be transparent

Ginzabe continues to make available information to help our users better understand Ginzabe’s processing of personal information and how to exercise choices regarding the use of your personal information through various channels including this Privacy Policy, applicable Notices and additional information that may be made available from time to time on various Ginzabe websites or your email address.

  1. You can access your personal information

Upon a written request, Ginzabe will inform you whether or not it holds personal information about you and provide you with access to your information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, Ginzabe will amend your information and notify any third parties as required by applicable laws.

In certain situations, and depending on applicable laws, Ginzabe may not be able to provide access to all of the personal information that it holds about you. For example, Ginzabe may not provide access to information if doing so:

  • would likely reveal personal information about a third party.
  • could reasonably be expected to threaten the life or security of another individual.
  • would reveal Ginzabe or third-party confidential information.
  • includes information that is protected by solicitor or attorney client privilege; or
  • includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.

In order to safeguard your personal information from unauthorized access, Ginzabe may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

Depending on the circumstances and applicable laws, Ginzabe may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

  1. Questions or concerns? How to contact us

Ginzabe welcomes your questions or comments regarding this Privacy Policy and the way we process your personal information. If you have any questions, concerns or wish to request access to your personal information pursuant to applicable privacy or data protection laws, please contact Ginzabe through by email at info@ginzabe.com.

  1. Managing your preferences

Generally, you may withdraw at any time your consent for Ginzabe to process your personal information in accordance with this Privacy Policy, subject to legal or contractual restrictions and reasonable notice. For example, although you can use Ginzabe Offerings for some purposes without providing us with any personal information, Ginzabe may need to process personal information for some services, including those that require payment or involve an ongoing relationship such as registration or subscription services. As such, Ginzabe may continue to use your personal information as may be required to provide you with requested services, and to the extent that Ginzabe is contractually obligated to do so or as necessary to enforce any contractual obligations you may have with Ginzabe. If you refuse to provide Ginzabe with the information it requires or later contact us in writing at the addresses above to withdraw your consent to use and disclose this information, Ginzabe may no longer be able to provide you with your Ginzabe Offerings.

  1. Changes to this Privacy Policy

Ginzabe will occasionally update this Privacy Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our users. Ginzabe encourages you to periodically review this Privacy Policy to stay informed of how Ginzabe manages your personal information. If any changes are made to this Privacy Policy, Ginzabe will revise the “Last Updated” date that is indicated on the Privacy Policy. If material changes are made that impact on you, we will notify users by placing a prominent notice at www.Ginzabe.com. Depending on the circumstances, we may also decide to send users a notice electronically. If you continue to use your Ginzabe Offerings after notice of the change has been given, you will be deemed to have accepted such changes.

Last Updated December 3, 2024.