principles, like end-to-end encryption of your messages and calls, which means we and third
parties can’t read or listen to them.
Your use of our services may involve the collection and use of Your Information (as defined hereunder) by us. It is important for You to understand how this happens and how You may control it, so please read this Policy carefully.
1. This Policy applies across all of our services as defined in Zulka’s Terms of Service.
3. Please also note that this Policy does not apply to Information collected: (i) through third party services (including any third party websites) that You may access through our services; or (ii) by other companies and organisations who advertise their services through our services.
(III) THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
“Information” includes Personal Information, Location Data, Log Data, Non-Personal Information, Sensitive Personal Information and Shared Information (all as defined below).In certain cases You will be given the option to not provide us with Your Information, in which case, if You decide to not share such Information, certain features within the Zulka App may not be available to You.
In providing our services, we collect, store and use the following information relating to You. Please note that all information is stored on our servers and synced regularly.
1. Personal Information
a. Depending on what services You use, Your Personal Information will be collected by us in different ways.
b. “Personal Information” is any information or combination of information that relates to You, and can be used to identify You. Personal Information may include, but will not be limited to the following:
i. Information You make available to us when You open an account or use our services, including but not limited to Your name, mobile number, gender, date of birth, residential address, push notification name (if applicable) and email address;
ii. Information which You make available to our services as You use them, including Shared Information You make available to others through our services and information You store using our services;
iii. Information relating to Your contacts and their details as listed in the address/phone book as stored on Your mobile and/or computer devices including but not limited to their names, mobile number(s), telephone numbers, dates of birth, email ids, etc.;
iv. You may have synced the device on which You have downloaded the Zulka App, with Your online email and social networking accounts, other mobile phones, computer and /or other similar electronic devices. As a result, the contacts and information stored on such online accounts, other mobile phones, computer and /or other similar electronic devices will be displayed on the device on which You have downloaded the Zulka App. You understand and agree that such synced information on Your mobile and computer devices forms part of the information mentioned in sub clause (iii) above and further agree that we will access, collect and store all such contacts and their information and details and sync them with our servers to enable You to communicate with Your contacts through the Zulka App, everywhere You go;
v. Information that other Zulka users make available about You in their use of our Services, such as information contained in posts they make and communications they make to You and others using our services;
vi. Information we collect as You use our services, including but not limited to certain Location Data and Log Data;
vii. Information related to “Your Interests”, which is voluntarily shared by You to on our services; and/or
viii. Billing information, provided by You at the time of purchase of premium in-app features and other Sensitive Personal Information.
c. Certain information relating to the hardware and software on Your mobile and computer devices will be accessed and processed in order to provide You with the services and functionalities that use such information. Such device information will include but will not be limited to device settings, time zone, network service provider information and IP address, software and hardware utilized in conjunction with Zulka App and the Site (for example, device PIN, IMEI, IMSI, UDID, MAC address or similar identifiers, and device model).
2. Non-Personal Information
a. “Non-Personal Information” is any information that relates to You but from which it is not practicable to directly or indirectly identify You, such as anonymous user usage data, referring / exit pages and URLs, platform types, asset views, clickstream data and includes Personal Information in aggregated, anonymised or pseudo-anonymised form.
3. Anonymous Information
a. “Anonymous Information” is such information like Your Google Advertisibng ID, your device type and version, browsing activity,location and other technical data relating to Your device in order to provide advertisements.
b. You provideYour express consent that we may collectand share Your anonymousinformationwith third partiestoserve advertisement when you visit our app.
4. Location Data
“Location Data” is information that we collect regarding Your current and saved location (when You use a location-enabled device), including:
i. The location of Your mobile and computer device when You use our services, such as from the GPS, WiFi, LAN, cell phone tower locations accelerometer or other similar satellite services or sensors in Your mobile and computer devices;
ii. The IP address of the device or internet service You use to access our services; and/or
iii. Other information made available by You or others that gives an indication as to where You are or have been located, such as account information that indicates where You are located and Shared Information You or others post indicating Your location, such as any geotag information that is embedded in any photos You make available to us.
5. Log Data
i. Technical information such as Your mobile carrier, configuration information made available by Your web browser or other programs You use to access our services, Your IP address and Your device’s version and identification number;
ii. Information about the state of Your device if the Zulka App crashes such as device model and build, device orientation, whether location services are active, operating system version, amount of memory free, amount of storage free and the amount of battery percentage;
iii. Information about what You have searched for and looked at while using our services, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by You in using our services;
iv. Information about communications You have made using our services, such as the people You’ve communicated with and the time, date and duration of Your communications; and
v. Metadata, which means information related to items You have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted.
6. Sensitive Personal Information
a. Sensitive Personal Information is information that relates to Your racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership of trade unions, physical or mental health conditions, sexual life information or any details of the commission or alleged commission of any offences by You or any order, judgment, sentence passed in relation thereto.
b. No Sensitive Personal Information will be accessed by us, unless the same has been voluntarily shared by You. All and any such Sensitive Personal Information collected by us from You will be deleted within thirty (30) days from the date on which You remove such information from the Zulka App or Your account with us is terminated or deleted for any reason whatsoever, whichever is earlier.
7. Shared Information
“Shared Information” is information about You or relating to You that is voluntarily shared by You on our services, including postings that You make on our services (including Your public profile, the lists and groups You create, last seen information, status updates, uploaded images, videos, audios), any postings from others that You re-post and including Location Data and Log Data associated with these postings.
(IV) HOW WE USE YOUR INFORMATION
1. We may use Your Information for any of the following purposes:
a. To provide and maintain our services to You;
b. For customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
c. To provide You with advertising and direct marketing that is more relevant to You (as discussed in more detail under the “Direct Marketing” section in the Zulka Terms of Service);
d. To provide You with more relevant content that is in line with Your interests;
e. To better understand how You access and use our services, for the purposes of trying to improve our services and to respond to Your desires and preferences, including language and location customisation, personalised help and instructions, or other responses to Your and other customers’ usage of our services;
f. To help us develop new services and features;
g. To improve the quality and design of our existing services;
h. To keep You, Your friends and the contacts listed in Your address/ phone book on Your mobile device informed andupdated on any of our new products and services;
i. To suggest friends in line with Your interests, based on the information shared by You;
j. To suggest third party services based on Your interests and location;
k. To investigate and prevent the misuse of any of our services;
l. To assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services when Your account is subscribed to an official account; and
m. To allow You to participate in surveys about our products and services. If You participate in a survey, we may request certain personal information from You. Participation in these surveys is voluntary and You therefore have a choice whether or not to disclose this information.
2. We may use a third party service provider to conduct these surveys and such third party service provider will be prohibited from using Your personal information for any purpose other than conducting the survey.
3. To use our services, You will have to provide us with a mobile telephone number that is valid within Your country of residence. You expressly acknowledge and agree that we may periodically access Your contact list and/or address/phone book and all its details as stored on Your mobile device and sync them with our servers to find and keep track of mobile phone numbers of other users and non-users of our services. For instance, when You register with us, the contacts listed on Your mobile device may receive an invite to download the Zulka App and register with us. The invite/message to Your contacts may appear as an SMS/message from You against Your name as may be saved on their mobile and computer devices. You understand that regular syncing of the contacts listed in Your address and phone book on Your device with our servers is necessary to enable You to connect and communicate with other Zulka users and therefore grant us permission to periodically sync your phone book contacts with our servers.
4. You further agree that in order to access certain functionalities on the Zulka App, we may collect email addresses, dates of birth and other details relating to Your contacts from Your mobile address and phone books.
5. Please note further that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where You have consented, Personal Information collected through our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).
6. For example, Personal Information collected during Your use of the Site may be used to suggest particular content that can be made available to You on the Zulka App or be used to try to present more relevant advertising to You. You may also be able to use, migrate or export Your Personal Information contained in one of our services to another of our services, where such option is available.
7. If any of your Personal Information comprises of Your Content (as defined in the Zulka Terms of Service), we and our affiliate companies may, subject to this Policy, use such Personal Information in accordance with the “Your Content” section of the Zulka Terms of Service.
8. Location data
a. Any Location Data sampled and saved by us will be sent to our servers so that we may associate the information relating to Your present location with Your interests and provide You with relevant promotional content including localized or time-sensitive offers, thereby providing You with a more customized experience with our services.
c. You may disable sharing of Location Data, by changing the settings on Your device, in which case You may not be able to access or use certain features within the Zulka App.
9. Billing Information
b. Any billing information that may be collected by us from You will be deleted thirty (30) days after Your account with us has been terminated or deleted.
(V) COOKIES, WEB BEACONS AND LOG FILES
(VI) SHARING OF YOUR PERSONAL INFORMATION
1. Other than as permitted under this Policy or as otherwise consented to by You, we will not pass your Personal Information to any other third parties for their processing for any purposes.
2. We and our affiliate companies may share Your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and You with location data), in each case, for the purposes of: (i) providing and maintaining our services to You; (ii) assisting us in carrying out the purposes mentioned above; (iii) carrying out our obligations and enforcing our rights under the Zulka Terms of Service or this Policy; and/or (iv) help understand and improve our services. These third parties may be located, and use and store Your Personal Information, outside of Your jurisdiction for these purposes.
4. You consent to the third party use, sharing and transfer of Your Personal Information, both inside and outside of Your jurisdiction, as described in this Policy. We will not transfer Your personal data and content to a third party or affiliate in any country or territory unless that country or territory ensures an adequate level of protection for Your rights and freedoms in relation to the processing, storing and retention of personal data.
(VII) A WORD ABOUT SHARED INFORMATION
1. Our services allow for Shared Information to be shared publicly with all users of that service and not just Your contacts. You expressly agree that Your “last seen”, “typing”, “profile photo”, “real name” and status submission will be seen globally by all users of the Zulka App who have Your mobile number and not just Your contacts, unless expressly blocked by You. So, if You do not want Your “last seen”, “typing”, “profile photo”, “real name” and status submissions to be globally viewed by users who have Your mobile number, it is recommended You change Your privacy settings to control public disclosure of such information.
2. Our services in particular are primarily designed to help You share Shared Information with the world via features either provided by us or third parties, so Shared Information can be broadly and instantly transmitted and will remain public for as long as You do not delete it.Please note that even after You delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us and will be deleted from our servers when You terminate or delete Your account with us.
3. Please consider carefully what You post and communicate through our services. Do not submit and share information that You would not want to be viewed publicly and globally. Any Information You share will be at Your own risk. In some instances, You may control what access the wider public has to Your Shared Information via the privacy settings in some of our services. To request the removal of an unauthorised account, please contact us at [email protected]
(VIII) COMMUNICATIONS FROM US
1. Newsletters and other types of communications
When You use our service, we may use Your Information to send You emails, newsletters, articles, text messages, in-app messages or push notifications to Your device.
2. Service-related announcements
We may from time to time send You service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
(IX) A WORD ABOUT SENSITIVE PERSONAL INFORMATION
1. In some jurisdictions, certain Personal Information, such as information about Your race or ethnic origin, religious or philosophical views or personal health, is characterised as “sensitive” and is subject to stricter regulation than other Personal Information. Please note that the content and Information that You input to our services, such as photographs or information about Your school or social activities, are done voluntarily by You and may reveal Your Sensitive Personal Information to others.
2. All and any such Sensitive Personal Information collected by us from You will be deleted within thirty (30) days from the date on which You remove such information from the Zulka App or Your account with us is terminated or deleted for any reason whatsoever, whichever is earlier. However, we urge You to consider whether it is appropriate to communicate Personal Information of a sensitive nature in the manner You are proposing to communicate it using our services, prior to posting such information.
(X) THIRD PARTY SERVICES ON OUR SERVICE
1. Our service may link You to, social media or other services (including websites) provided by third parties. For example:
a. We may (whether in advertisements or otherwise within our services) provide You with links that allow You to access third party services or websites;
(XI) AGE RESTRICTIONS
1. As contained in Zulka’s Terms of Service, children under the age of 13 are not allowed to use our services.Users will be able to claim their prize in the Weekly Prize Draws that may be held only if they are at least 16 years of age if resident in the UK, USA & DC (excluding Florida & New York), or at least 18 years of age if resident in India. .We do not knowingly collect Personal Information from any children under the age of 13. Please contact us at [email protected] if You believe we have any Personal Information from any children under the age of 13 and we will promptly investigate (and endeavour to remove) such Personal Information.
2. We reserve the right to delete or deactivate an account of auser who is found to be under the age of 13. Upon such deactivation, we will endeavour to permanently delete all Information shared by such users.
(XII) TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION:
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which Your Personal Information is used and stored may not be in Your jurisdiction.
2. In our service, we use encryption technology to protect certain Information (such as messages, contact and phone / address book details, images, videos and audios). Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which You access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If You have any questions regarding the security of Your Personal Information, please contact us at [email protected]
3. The messages sent by You to any other user of the Zulka App shall be stored for a period of seven (7) days, once received by the other user. After the period of seven (7) days expires, the message is no longer stored on our servers. If the message has not been delivered to the user as a result of him/her being offline, then the message remains on the server for a period of forty five (45) days, after which the undelivered message will be deleted.
4. The personal information shared by You at the time of Your registration for our services will be stored by us for a fixed period of time, after which it will be permanently deleted. By using our services You expressly consent that Your Personal Information may be used by us and our affiliate companies for a period of ten years from the date of termination or deactivation of Your account, whichever is earlier. We store Your Personal Information for sending You and Your contacts information about any improvements, enhancements and updates in our existing services and any new services and products launched by us, which in our opinion, may be of interestto You or which may help to bring You back to our services, should You have terminated Your account with us. You and Your contacts will be given the option to opt-out of such promotional and marketing messages. If You and/or Your contacts choose to opt out, You will no longer receive any of our marketing and advertising promotional messages and we will permanently delete Your personal information held by us.
(XIV) PERIOD OF USE OF YOUR PERSONAL INFORMATION
2. Subject to applicable laws and regulations, You may have the right to request to receive a copy of and make any corrections to Your Personal Information which we hold, and to request that we deactivate and not use any of Your Personal Information that is stored by us. You may direct such a request to us, or where we offer this option in our services, You may also log into Your account with us and make the appropriate changes. We will respond to all requests made to us within 40 working days.
3. It is important to note that, even after Your account may be terminated with us, for whatever reason, communications made by You using our services may put Your Personal Information in the hands of third parties that we cannot control.
Version 3: Last updated 29th May 2018