Zula, Inc. (in this Policy: “us“, “we” and “our“) respects your privacy. This Policy (the “Policy”) explains our privacy practices for our Services at www.zulaapp.com and any related domain names as well as through our “ZULA” mobile application (collectively – the “Service” or the “Services”). It describes the ways your personal information and data is collected and used and the rights and options available to you with respect to your information.
Information that we process
We process the following types of information –
(1) Device and traffic information – information identifying and relating to your computer and mobile device and communication and transmission data that your computer and mobile device generates when you use the Service;
(2) Personal details – Information that you provide us when you register to the Service or when you communicate with us or other users of the Service, including your native mobile phonebook and any personal information that becomes available to us when you register to the Service through a social network account, such as your basic profile information, your contacts, email addresses, photos/videos and any other content available therein (in accordance with your privacy settings on any such social network).
The following sections of this Policy provide additional details on each type of information that we collect and what we do with that information.
Device and traffic information
We collect data related to your use of the Service, such as information about the frequency of your use of the Service and content that you viewed, created or uploaded when using the Service. We may collect communication and transmission data that your computer and mobile device generates or stores to help us provide the Service. For example, we may collect and receive the operating system version and IP address you use once you register to the Service.
Personal Information that you Provide to Us
Use of the Service and the creation of a personal account are available to registered users only. When you register with the Service we may ask you to provide us with certain contact information and personal details, such as your full name and an active e-mail address and to enter a username and password or provide other details or attributes that define you as a user (such as your profile picture). We may collect additional information, as required, when we exchange communications with you.
Registration may also available through some social networks accounts, such as Facebook, Google+ and LinkedIn. When registering through your social network account, you are allowing us access to your basic profile information (such as your name, age, email address, geo-location and your contacts/friends/followers). We can only access the information that your social network operator makes available to us, according to your privacy settings on such social network.
After you have signed-up, we will ask for your permission to access your mobile phonebook. By consenting, you give us permission to retrieve your existing contacts, as well as new contacts that you may subsequently add. We will use this information to allow you to send your contacts invitations to use our Services, and for additional purposes outlined in this Policy. You may, at any time, opt-out of sharing this information through the settings menu of our mobile application.
Keep in mind that phonebook contacts that you give us access to or share with us, and other information you actively submit (collectively, “Content”), may contain or be indicative of, your own or third parties’ personal information or private affairs (depending on the particulars of the Content). Such Content is not treated as private or confidential and you should not have any expectation of privacy with respect to it.
BECAUSE THE CONTENT MAY HAVE TO DO WITH THE PRIVACY OF OTHERS, YOU MUST LAWFULLY OBTAIN THE CONSENT OF ALL INDIVIDUALS WHOSE PERSONAL INFORMATION OR PRIVATE AFFAIRS MAY BE REFLECTED IN THE CONTENT. USE CAUTION AND COMMON SENSE WHEN YOU SHARE WITH US CONTENT THAT MAY BE INDICATIVE OF PERSONAL INFORMATION ABOUT YOURSELF OR OTHER INDIVIDUALS. YOU ARE SOLELY RESPONSIBLE FOR ANY CONTENT THAT YOU SHARE WITH US.
You may optionally provide a photo of you, to be displayed as your profile picture on the Service. If you choose to do so, the App will access your smartphone’s camera (to snap a photo of you) or memory storage (to let you select an existing photo).
Communications with other users
Bear in mind that when you upload your content to the Service, it may be displayed to other users of the Service. As soon as your content is displayed publicly, it will not be considered private or confidential and you should not have any expectation of privacy with respect to it.
PLEASE USE CAUTION AND COMMON SENSE WHEN YOU UPLOAD ANY PERSONALLY IDENTIFIABLE INFORMATION OR GEOGRAPHIC LOCATIONS. YOU ARE SOLELY RESPONSIBLE FOR ANY CONTENT AND INFORMATION THAT YOU UPLOAD.
The ways we use your personally identifiable information
We may use personally identifiable information for the following purposes –
- To provide you with the Service, its features and functionalities.
- To send you notices and updates, to conduct surveys related to the Service and to provide you with information related to the Service – through the Service interface or through e-mail, as available.
- To respond to messages that you send us, and to allow us to provide support and assistance.
- To improve and customize your and other users’ experience with the Service.
- To enhance existing features of the Service and to develop new features and services.
- To prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service.
- To facilitate our internal managerial, archival, administrative and audit activities.
- To contact you as and when we believe it to be necessary.
- To comply with any applicable law and assist law enforcement agencies or competent authorities under any applicable law, when we have a good faith belief that our cooperation with such entities is legally mandated or meets the applicable legal standards.
- To prevent imminent physical harm or damage to property.
- To take any action in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties with respect to, or in relation with the Service.
Sharing information with others
We may share personally identifiable information with others in any of the following instances, or subject to your explicit consent:
- To operate, maintain and enhance the Service;
- If you have breached any terms, abused your rights to use the Service, or violated any applicable law. Your information may be shared with competent authorities and with any third party, as may be required;
- If we reasonably believe that we are required by law to share or disclose your information;
- In any case of dispute, or legal proceeding of any kind involving you with respect to the Service;
- If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration; and
- Personally identifiable information may be shared with our subsidiaries, sister-companies and parent companies, but their use of such information must comply with the Policy.
In any case other than the above, your personally identifiable information will be shared with others only if you provide your explicit prior consent.
Transfer of data outside your territory
The Service, by its nature as an online service, may store and process information and Content (including through Cloud Services) in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide us with your express and unambiguous consent to such transfer.
We use de-identified or aggregated information
We may use de-identified, statistical or aggregated information, including information that we process according to this policy, to properly operate the Service, to develop and improve the quality and functionality of the Service, to enhance your experience, to create new services, including customized services, to change or cancel existing features and for other research, development and statistical purposes. We may share, publish, post, disseminate, transmit or otherwise communicate or make available such information to suppliers, business partners, sponsors, developers, affiliates and any other third party, at our sole discretion, provided however, that we will not knowingly, or intentionally share information that can be reasonably used to reveal your identity without your consent.
Access to your personal information
You have a right to access your personally identifiable information if, and to the extent, we keep such data about you, and to update, rectify or remove such data. To apply for a copy of your information, please contact us at: firstname.lastname@example.org.
Before allowing you to exercise your right, we will need to verify your identity. We will make the information available to you, subject to any legitimate constraints and pursuant to the applicable law. We may refuse your request, for example, if we are unable to identify you, or if we believe that removal of certain information may jeopardize activities or features of the Service, harm other users, or compromise our legal rights.
We may provide you additional options to delete your personal information through the settings and preferences features of the Service. You may access your account and edit or amend the personal details that you provided during registration at any time, through your account settings or by updating the information of your social network account that you provided to register with the Service. If you find that the information on your account is not accurate, complete or updated, then you may make all necessary changes to correct it.
Some of the Cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block our cookies, you may do so by clicking the “options” button on your browser’s menu and follow the necessary instructions. You can read your browser’s Help file of for further information. However, bear in mind that disabling cookies may complicate or even prevent the use of the Services, or certain features thereof.
Securing your personal information
We and third parties on our behalf implement security measures to secure the information we store and process. While such security measures reduce the risk of security breaches, they do not provide absolute security. Therefore, while we take reasonable measures to secure the information, we cannot guarantee that it will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access.
We retain different types of personally identifiable information for different periods, depending on the purposes for processing the information and our legitimate business purposes. When we no longer need to process the information that identifies you, we may take measures to de-identify the information.
Generally, as long as you are a user of the Service, we do not delete information related to you, unless there are technical reasons that require us to retain only portions of the data, or if we are required by law to delete it.
Please note that we will retain and disclose information when we deem it necessary to satisfy orders issued by courts and government authorities. We will notify you about the disclosure, only if we are explicitly permitted to do so. In any case, we may keep any aggregated or anonymous information for statistical, development, marketing and other purposes, indefinitely.
Important notice about children’s privacy
We do not allow children under the age of 13 to use the Service. If you are not yet 13 years of age, then you may not use the Service and must not provide any personal details to us.
We do not intentionally collect personal information about children who are under 13 years of age. If we learn that a child under the age of 13 provided personally identifiable information to us without verifiable parental consent, we will use commercially reasonable efforts to delete such information from our databases.
We strongly encourage parents to monitor their children’s use of online and mobile applications. We will delete a child’s personally identifiable information if a parent so requests by contacting us at email@example.com.
Changes to this Policy
From time to time, we may change and update the terms of this Policy. Technical changes in the Service, new features and evolvement of relevant legal aspects, will require us to adapt this Policy.
We will notify you, either through the Service, or through any other means, in our discretion, of any substantial change that we make to this Policy. The changes will apply to you seven (7) days following transmission of the display of the notice to you. You agree to be bound by all changes made in the terms of this Policy. Continuing to use the Service after that date will indicate your acceptance to the amended policy. If you do not agree with any of the amended terms, you must avoid any further use of the Service.
We may also amend this Policy to comply with any legal requirements. In these cases, the amendments will become effective as required or ordered and we will send you a notice of such change.
We are doing our utmost to comply with this Policy. If you have any questions, concerns or complaints regarding this policy, please refer them to: firstname.lastname@example.org. After receiving your request, we may contact you to better understand your concerns and will make all efforts to promptly answer your question, or resolve your complaint.
Last updated: July 2015