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PRIVACY POLICY

To review material modifications and their effective dates scroll to the bottom of the page.

The Zulution LLC consisting of Zulution LLC  (“Zulution LLC”) owns and operates this zulution.com  website business, including any add-on mobile applications we may offer. All references to “we”, “us”, this “website” or this “site” shall be construed to mean the Zulution LLC.com website, any add-on mobile applications we may offer, and the Zulution LLC

Our Privacy Policy applies to all of the services offered by us and our affiliated entities, including services accessed by mobile devices and application programming interface (API), but excludes services that have separate privacy policies which do not incorporate this Privacy Policy.

Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, web beacons (pixel tags), and other methodologies to serve personalized ads.

HOW WE MODIFY THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy that is always accessible by clicking on the “Privacy Policy” link on this site’s home page. Your continued use of this site indicates your acceptance of the amended Privacy Policy.

Regarding Personal Information (defined below), if any modifications are materially less restrictive on our use or disclosure of the Personal Information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.

THE TYPES OF INFORMATION WE COLLECT

Personal Information. “Personal Information” includes any information regarding a natural person that may be used directly to identify the person. Personal Information that we collect may vary with each separate purpose for which you provide it, and it may include one or more of the following categories: name, physical address, an email address, phone number, credit card information including credit card number, expiration date, and billing address, and location data.

Passively or Automatically Collected Data (“Usage Data”). We, our affiliated entities, and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access this site or its services. This information is based on your usage of this site, including information collected automatically from this site (or by our marketing partners employed in this site). Usage Data may include: the IP addresses or domain names of the computers utilized by the users who use this site, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the site) and the details about the path followed within the site with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user’s IT environment. Usage Data is essentially anonymous when collected, but could be used indirectly to identify a person.

HOW AND WHEN WE COLLECT INFORMATION

Personal Information. We collect Personal Information at the time you provide it to us. We collect Personal Information through sign-up forms and as part of your registration for an account, product, or service, promotion, or contest from this website. Personal Information that we collect may vary with the each sign-up or registration. In addition, we collect personal information from all communications with site visitors including without limitation, text messages, faxes, telephone calls, and regular “snail mail”, as well as from third-party outside sources including database vendors.

Your Communications With Us. We collect Personal Information that we receive from you as you communicate with us. If you complete a signup form subscribing to information from our site or to participate in our mailing list activities, we will receive your Personal Information from our email services and/or autoresponder service.

Usage Data. We collect Usage Data as you use this site, including your interactions with emails we send, and via social media platforms, third-party platforms, third-party websites, applications, integrations, and services of our marketing partners. This data may be passively or automatically collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies, web beacons, locally stored objects, and mobile device identifiers and SDKs, and other similar methodologies as well as similar technologies developed in the future.

HOW WE USE YOUR INFORMATION

We may use your Personal Information for the performance of the services or transaction for which it was given, and in connection with other products, services, promotions, or contests we may offer, and our private, internal reporting for this site, and security assessments for this site.

Personal Information about you or another person may be included in electronic communications or transactions submitted to our systems for processing or transmission. We will only process such Personal Information for the purpose of effectively providing the relevant service to you. Your electronic communications or transactions may be stored on our live systems or in our data archives for operational purposes such as reporting and trouble shooting. We delete message content completely from our systems and data archives when it is no longer required for operational purposes and in accordance with our internal company policies. By submitting electronic communications or transactions containing Personal Information of other persons to us for transmission, you confirm that you have obtained the explicit consent of each such other person for us to process and store their Personal Information. We do not accept any liability resulting from our processing or storage of Personal Information you submit to our systems for which you do not have the necessary consent.

We process and archive Personal Information in the form of mobile phone numbers used in our services. By submitting electronic communications to us for transmission to recipients, you confirm that you have obtained the explicit consent of each recipient for us to process and store their mobile phone numbers. By submitting transactions to our systems for processing or allowing others to do so, you confirm that the following persons have given their express consent for us to process and store their mobile numbers: (i) the subscriber from whose mobile number a transaction is initiated, and (ii) in the event of direct prepaid airtime top-up, the subscriber whose mobile number is topped up as a result of a transaction done via our systems. We do not accept any liability resulting from our processing or storage of mobile phone numbers during the provision of our services. 

We may make full, unrestricted use of Usage Data for any purpose in our sole discretion, including without limitation, to customize or personalize ads, offers and content made available to you based on your visits to and/or usage of this site or its services, and to analyze the performance of those ads, offers and content, as well as your interaction with them.

INFORMATION SHARING AND DISCLOSURE

General Disclosure Policy.   We reserve the right to disclose your Personal Information as described below. We reserve the right to disclose Usage Data without restriction.

Affiliated Entities. We reserve the right to provide your Personal Information and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.

Service Providers. We reserve the right to provide access to your Personal Information and Usage Data to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting services. Our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your Personal Information and Usage Data.   In such an event, we will require the buyer or transferee to agree to our commitments provided in this Privacy Policy.

Legal Process, Enforcement and Security Notice. We reserve the right to disclose your Personal Information and Usage Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site.

Affiliates And Joint Venture Partners. We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions, or contests. We may right to disclose your Personal Information and Usage Data to them for purposes of (i) compensation, transaction processing, fulfillment, and support, and (ii) for purposes of offering you other products, services, promotions, and contests. These joint venture marketing partners may also contact you regarding other products, services, promotions, or contests.

Marketing Partners. We may share your Personal Information and Usage Data with our marketing partners to serve and offer personalized ads.

Your California Privacy Rights. Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase “California Privacy Request” in the subject line, the domain name of the Web site you are inquiring about, along with your name, address and email address. We will respond to you within thirty days of receiving such a request.

SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS

In order to provide better service for our site, we may use Cookies and Web Beacons to collect Usage Data to store your preferences and information about what pages you visit and past activity at our site. We may also employ Web Beacons from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our site.

“Cookies” are tiny pieces of information stored by your browser on your computer’s hard drive. Cookies are also used to customize content based on your browser.   Most browsers are initially set to accept cookies.   If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies.   Please remember, however, that cookies may be required to allow you to use certain features of our site.

Flash Cookies – third party cookies that use an Adobe Flash Media Player local shared object (LSO) – may be used along with other third party cookies for purposes of crediting any purchase you may make on this site to one of our joint venture marketing partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as “browser cookies”. The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.

Web Beacons – sometimes called single-pixel gifs or clear gifs – are used to assist in delivering cookies, and they allow us to count users who have visited pages of our site. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.

PERSONALIZED ADS

We may participate with our marketing partners for purposes of providing personalized ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage advertising activities.

Our marketing partners may also use cookies and other tracking and data collection methodologies discussed above to measure advertisement effectiveness and for other purposes that are disclosed in their own privacy policies. We have no access or control over these cookies and other tracking and data collection methodologies that may be used by our marketing partners, and we have no responsibility or liability for the privacy policies and practices of these sites.

AdWords Remarketing (Google) – We reserve the right to participate in AdWords Remarketing which is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit https://support.google.com/ads/answer/2662922?hl=en

Remarketing through Google Analytics for Display Advertising (Google) – We reserve the right to participate in any and all of the following Google Analytics Advertising Features provided by Google Inc. –   Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out, visit https://support.google.com/ads/answer/2662922?hl=en You may optout of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout/

For information in general about Google’s remarketing ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google’s advertising cookies for these campaigns, visit http://www.google.com/policies/technologies/ads/

For another Google resource for opting out of Google’s use of cookies, visit http://www.google.com/settings/ads

For information regarding how Google uses data when you use Google’s partners’ sites or apps, visit http://www.google.com/policies/privacy/partners/

For another resource recommended by Google for opting out of a third party vendor’s use of cookies, visit http://www.networkadvertising.org/managing/opt_out.asp

Custom Audience (Facebook). We reserve the right to participate in Facebook.com’s Custom Audience. A Custom Audience on Facebook.com enables us to display to persons on our email lists targeted, personalized ads when they visit Facebook.com. The ads are based on your shopping experience at our website. No personal information, including your shopping history, is shared with Facebook. The Custom Audience allows us to convert your email address to a unique number that Facebook uses to match to unique numbers that Facebook generates from email addresses of its users. You may optout of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the email address provided in our contact information below. For your optout to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.

Other Remarketing Services. We reserve the right to participate in additional remarketing services that will be similar to the remarketing services described above. These services will allow us and our partners to display ads that are likely to be more relevant (such as behavioral or targeted ads that are based on information about your browsing history). You may access these services to opt out: http://www.networkadvertising.org/choices/ http://www.digitaladvertisingalliance.org/ and http://www.aboutads.info/choices/

ANALYTICS

We reserve the right to participate with third party analytics partners to monitor and analyze Web traffic and can be used to keep track of user behavior on this site.

Google Analytics (Google) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of this site, to prepare reports on its activities, and to share them with other Google services. Information collected: cookie and Usage Data. Visit Privacy Policy at https://www.google.com/intl/en/policies/?fg=1 You may optout of the Google Analytics service with the Google’s Browser Add-on that’s available at https://tools.google.com/dlpage/gaoptout/

SOCIAL MEDIA INTERACTIONS

We invite you to socialize and share your participation with this site and purchases. If you choose to use social media platforms such as Facebook, Twitter, Pinterest, and Instagram, you will be allowing interaction with these platforms or other external platforms directly from this site, and in the process you may be sharing certain profile elements, including your comments. This sharing is subject to each social media program’s privacy policies.

DO NOT TRACK REQUESTS

Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.

DATA SECURITY

We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site.

When you transmit Personal Information through our registration process or if you purchase products or services, we encrypt that information in transit using secure socket layer technology (SSL).

ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE (TRANS-BORDER SUBMISSIONS)

Personal Information collected or processed by us may be shared between companies within our affiliated companies or may be processed by third party service providers. For these purposes, Personal Information may be processed cross-border, and by submitting personal information on our site or through our systems, you explicitly consent to trans-border transmission of your Personal Information.

IF YOU PROVIDE PERSONAL INFORMATION ABOUT ANOTHER PERSON

We only collect or process Personal Information if it is specifically and voluntarily provided by you or as otherwise disclosed in this Privacy Policy. If you provide us with Personal Information about another person, you warrant that you have that person’s consent to do so and that such person has given explicit consent for us to collect or process their Personal Information for the purpose for which you submitted it to us.

UPDATING AND ACCURACY OF PERSONAL INFORMATION

Subject to applicable law, upon request, we will permit you to request or make changes or updates to your Personal Information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Information in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.

We do not assume responsibility for verifying the ongoing accuracy of Personal information. When practically possible, if we are informed that any Personal Information submitted to our site or systems and stored by us is no longer accurate, we will make appropriate changes; however, we will not be liable for any damage that you may suffer from any cause whatsoever due to inaccurate information being provided to us or a failure to update information.

LINKS TO JOINT VENTURE MARKETING PARTNER SITES

This site may contain links to other websites operated by our joint venture marketing partners. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them.

CHILDREN’S ONLINE POLICY

We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact:

Zulution LLC
Attn: Privacy Policy Officer
Email: contact@zulution.com

Material Modifications Since 22 Nov, 2016: none.