Privacy Policy


The Company processes a number of personal data of Users, Sellers or Buyers  when using ZWAP Services. This privacy policy ("Policy") describes what types of personal data are processed, how they are used, what your options are in relation to such processing, and how We will respect your rights in this process. As a data subject under personal data protection legislation, including Regulation (EU) 2016/679 (“GDPR”). BEFORE USING ZWAP MARKETPLACE or the ZWAP APPLICATION OR OUR SERVICES, WE RECOMMEND YOU TO READ THIS POLICY CAREFULLY TO UNDERSTAND HOW YOUR PERSONAL DATA IS PROCESSED.


Who is responsible for processing your data? Pierre Monclaire S.R.L., based in Prel Sgt N Grindeanu No. 1 Constanta, Romania, is the controller of personal data, according to the legislation on personal data protection including GDPR, regarding the personal data of Users collected and processed through ZWAPTHEAPP.COM AND ZWAP APPLICATION. Regarding the data collected through cookies for marketing purposes (for details see the Cookies Policy section. What data do we process? We process the following categories of personal data: Data that you provide directly User account creation When you create a  USER account, you must provide us with a number of details, such as e-mail address / no. mobile phone .

Data from the Registered User Profile You can include a range of information in your user profile, as well as PERSONAL BELONGINGS DETAILS, Other data you provide directly when you use the ZWAP Platform or interact with ZWAP We may store the information we have received from you as a result of requests sent by e-mail or chat, or when you participate in our surveys and questionnaires; Also, if you use our CHAT SYSTEM we can process your image and voice through the online services implemented in the ZWAP Platform, and we can access the conversations . Data collected or generated by us as a result of your interaction with the ZWAP Platform


We record information about when and / or how you visit or otherwise use the ZWAP Services, including how you use the ZWAP Platform (whether or not you have updated your ADS, whether or not you have VIEWED OR SAVED OR POST AD) We also use cookies and similar technologies to recognize you and your devices. We also allow other people to use cookies. How we use these technologies is described in the Cookies Policy. Also, when you use the ZWAP Platform (including cookies or similar technologies on other people's sites), we receive information about your IP address, IP-based location, proxy server, operating system, web browser, and add-ons, device identifier. If you use our services from a mobile device, that device will send us data about your geographic location, based on the settings of the mobile device you are using. We'll ask you to opt-in before using the geolocation feature or other tools to identify your location. Data obtained from third parties We receive information about your visits and interaction with services provided by other entities when you visit the services of other providers that include advertisements, cookies, or similar technologies. In the case of contacts designated by Users (other than account holders), the data is collected from the respective account holder.


Why do we process your personal data? In the following, we will inform you about the purposes for which we collect and process your personal data, as well as the legal basis for the processing of your data. 3.1. Use of the Services by BUYERS AND SELLERS Users If you want to enjoy all the facilities offered by the ZWAP Platform, you need to create a User account. The User Account allows you to access a range of Services dedicated to Users, such as creating a AN AD, LIKE, ADD TO WISHLIST, CHAT etc. Legal basis: art. 6 (1) (b) GDPR - conclusion and execution of the contract. The ZWAP Platform can also be accessed by Users from abroad, including from outside the European Economic Area, to jurisdictions that have not been granted an adequate level of protection. your data may be transferred to such a jurisdiction, and the legal basis for the transfer is art. 6 (1) (b) GDPR - conclusion and execution of the contract. We may also use some of the data you provide to us to optimize how we make ADS suggestions or suggestions to complete your ADS. We also use the data we receive from Users to create filtering facilities for Users/ADS based on various criteria of interest to OTHER Users. Legal basis: art. 6 (1) (f) GDPR - legitimate interest. We have a legitimate interest in improving our Services and providing suggestions / advice to SELLERS/BUYERS Users to maximize the success of our Services. At the same time, we want to provide an indicator search service that is as efficient as possible for BUYERS AND SELLERS.

3.2. Use of the Services by DEALERS Users We process personal data in order to manage the contractual or pre-contractual relationship with the BUYERS Users. In the case of DEALERS (authorized natural persons) the legal basis is: art. 6 (1) (b) GDPR - conclusion and execution of the contract or performance of pre-contractual formalities. In the case of personal data of the representatives of the Users, the legal basis is art. 6 (1) (f) GDPR - legitimate interest. We have a legitimate interest in properly conducting our contractual relationships with our corporate clients. The rights and interests of individuals (i.e. representatives of Users) are not prejudiced because from the perspective of the legal person client, processing is necessary in the context of working / collaboration relations they have with individuals whose data are provided / associated with the User's account. Also, based on legitimate interest, we use certain personal data associated with a User account to prevent possible fraud / misuse of the facilities offered by the ZWAP Users Platform. 3.3. User relationship management and support We process a number of personal data in order to manage relationships with Users of the ZWAP Platform, for example when they contact us with various questions or requests regarding the functionalities or malfunctions of the ZWAP Platform. Legal basis: art. 6 (1) (f) GDPR - legitimate interest in our interest to provide adequate services to all Users. 3.4. Providing communications regarding the Services Users may receive various communications from Us related to the provision of the SERVICES (NEW POSTS, NEW MESSAGE, NEW SAVED)  We process this data based on our legitimate interest art. 6 (1) (f) GDPR. We believe that our legitimate interest does not violate the rights and interests of data subjects as communications are closely ZWAP to the provision of the Services requested. 

Providing commercial communications We would like to send you promotional materials, inform you about new services offered by the Company, invite you to participate in surveys or to answer questionnaires, and to share other similar information that we think may be of interest to you. including, if you agree, the transmission of promotional materials / marketing communications regarding the products / services of the Company's partners. We will send you these communications if we have your consent. Legal basis: art. 6 (1) (a) GDPR - consent. Users can unsubscribe from these communications at any time. For example, if you withdraw your consent for content communications (Newsletters), we will no longer be able to send you our articles published on content platforms. Also, if we have consent to commercial communications, in certain situations, we may use the information we collect from you in combination with data resulting from your interaction with ZWAP Platform Services, which we may use in the context of our marketing communications. The legal basis for such processing is: art. 6 (1) (f) GDPR - legitimate interest. We want to streamline our marketing business by offering our customers relevant and personalized service offerings. 3.5. Use of geolocation services When using the geolocation feature of your device, we'll ask for your consent. Legal basis of processing: art. 6 (1) (f) GDPR - consent. 3.6. Analyzes and statistics on the operation of the ZWAP Platform, cookies and similar technologies

We may use or disclose personal data that you provide to Users in the context of your use of the Services in order to perform analyzes and statistics about our Services, including how the ZWAP Platform operates. The legal basis for such processing is: art. 6 (1) (f) GDPR - legitimate interest. The analysis and statistics we provide help us to better understand how we can improve our Services or the functionality of the ZWAP Platform. We also use cookies and other similar technologies in our analysis of cookies and statistics in accordance with the Cookies Policy. Depending on the type of cookies used and similar technologies, the legal basis is: art. 6 (1) (f) GDPR - legitimate interest for the necessary and functional cookies or art. 6 (1) (a) GDPR - consent for analysis, tracking and behavioral advertising cookies. 3.7. Login via Facebook, Google, linkedin plugin Candidate users can log in or create an account through the Facebook plugin, google, linkedin, which allows them to connect through their personal Facebook account. When Candidate Users use this feature, the ZWAP Platform partially retrieves the public data of the Candidate User from Facebook (e.g. last name, first name, email address, phone number). The use of these data is necessary for the creation of the User account, therefore the legal basis of the processing is art. 6 (1) (b) of the GDPR, respectively the conclusion and execution of the contract. 3.8. Fulfillment of legal obligations Sometimes, the processing of data is necessary in order to fulfill our legal obligations (Legal basis: art. 6 (1) (c) GDPR - execution of a legal obligation) which are incumbent on us, such as:

payment of relevant taxes and contributions, reporting to the relevant tax authorities and keeping records; archiving data in accordance with applicable law. 3.9. Defending the rights and interests in the judiciary We may also process personal data for the purpose of ascertaining, exercising or defending a right in court in proceedings before a court, administrative proceedings or other official proceedings in which the Company is involved (Legal basis: art. 6 (1) (f) GDPR - protection of the rights and interests of the operator). To whom do we disclose the data? We may disclose your personal data to (i) entities and / or persons authorized by us (in the EEA or in third countries) involved in the provision of the Services, including the provision of commercial communications (such as data center providers, service providers). payment for various payment facilities in the ZWAP platform, providers of e-mailing platforms such as Google Mail); (ii) Users including, where applicable, those outside the EEA; (iii) if we have an obligation to disclose personal data in order to comply with any legal obligation or decision of a judicial authority, public authority or governmental body; or (iv) if we are required or otherwise permitted to do so in accordance with applicable law. Your personal data may also be disclosed to third party providers of cookies and similar technologies as described in the Cookies Policy.


How long do we keep the data? We will keep your personal data as necessary for the purposes for which it was collected, in accordance with internal data retention procedures, including applicable archiving rules. In general, Candidate User Data is retained as long as it has a User account in the ZWAP Platform. Personal data will be deleted if the Candidate User requests deactivation and deletion of the account, or after a period of at least 5 years from the date on which the Candidate User becomes inactive (i.e. from the date of the last interaction in the ZWAP Platform). The data of the Users (authorized natural persons and representatives of legal entities) will be kept for the entire duration of the contractual relations with the User, plus for the entire period provided by law for the activity of archiving and keeping financial-accounting documents. Data related to cookies and similar technologies are stored according to the specific deadlines set for those technologies, the storage period can be between the duration of the browsing session (for session cookies) and a duration of up to 2 years (for cookies analyze). What rights do you have as a data subject? By law, you have the following rights as a data subject: Right of access You can obtain confirmation from us that we process your personal data, as well as information on the specifics of the processing. The right to correct data You can ask us to change your personal data incorrectly or, if necessary, to fill in data that is incomplete. The right to delete : You may request the deletion of personal data when: (i) they are no longer necessary for the purposes for which we collected and process them; (ii) you have withdrawn your consent to the processing of data and we may no longer process them on other legal grounds; (iii) the data are processed unlawfully; respectively (iv) the data must be deleted in accordance with the relevant legislation. Withdrawal of consent and right of opposition You can withdraw your consent to the processing of data at any time by consent. You may also oppose any processing for marketing purposes, including profiling performed for this purpose, as well as DATA processing.