This Privacy & Security Policy applies to the Zulu Labs Pty Ltd (ABN 51 603 188 807) Zulu Labs Australia Pty Ltd (ABN 79 13 9333 949) ("Zulu Labs").
This policy was last updated July 1 2018.
The terms "we", "us" or "our" means Zulu Labs or a Relevant Related Company (where applicable).
Collection of Personal Information
We will not ordinarily collect any information about you except where you provide it to us or it is provided to us with your authority.
The types of personal information we collect generally includes your name, address, telephone number, email address and shipping details, account activity and general marketing analytics such as Clicks, preferences and so on. We also integrate with third party applications to enhance our understanding of your needs and behaviours only in terms of information that we have gather through general business channels.,
In certain circumstances, we may also collect personal information about you which is sensitive. Sensitive information includes information about your health, religious or philosophical beliefs, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection. If the sensitive information relates directly to your ability to meet a financial obligation to us, you consent to our collection of it.
We will collect personal information directly from you when you open an account with us, complete an application form for one of our products or services, deal with us over the telephone or in person, send us a letter or visit our website. We may, for purposes of security, training, or information or transaction verification, listen to and/or record telephone calls to which you are a party with us.
On occasions, we may need to collect personal information about you from third parties, such as credit reporting agencies, our business alliance partners, your agents or third party brokers. If your consent to this collection is required by law, we will first obtain your consent prior to collecting the information.
We only collect personal information about you that is necessary for our functions and activities and, ordinarily, you will be told the purposes for which we collect that information when it is collected.
As a general rule the collection of your personal information will be necessary for us to provide a product or service to you or to maintain our relationship with you.
Additionally, the purposes for which we will generally collect and use your personal information will include:
complying with legislative and regulatory requirements;
considering any application you make to us;
performing our administrative operations, including accounting, risk management, record keeping, archiving, systems development and testing, credit scoring and staff training;
managing our rights and obligations in relation to external payment systems;
conducting market or customer satisfaction research;
developing, establishing and administering alliances and other arrangements (including rewards programs) with other organisations in relation to the promotion, administration and use of our respective products and services;
developing and identifying products and services that may interest you; and
(unless you ask us not to) telling you about products and services.
<h3>Personal Information About Third Parties</h3>
If at any time you supply us with personal information about another person (for example, a date of birth or a person to whom you may wish a payment to be directed), you should ensure that you are authorised to do so and you must agree to inform that person who we are, that we will use and disclose their personal information and that they may gain access to their personal information should we hold it.
Use and Disclosure of Personal Information
We will not use or disclose information collected about you other than for a purpose made known to you, a purpose you would reasonably expect, a purpose required or permitted by or under any law or a purpose otherwise authorised by you.
You authorise us to disclose necessary information to related companies and to any agents or contractors who provide services to us in connection with the provision of products or services you have sought from us.
These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.
Subject to what is permitted by law, the types of third parties we may disclose your personal information to include, where relevant:
credit reporting agencies;
our agents, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions and activities;
your agents and contractors, including your finance broker, builder and settlement agent and your legal or financial adviser;
your executor, administrator, trustee, guardian or attorney;
regulatory bodies, government agencies, law enforcement bodies and courts;
any person or organisation who introduces you to us;
other organisations with whom we have alliances or arrangements (including rewards programs) for the purpose of promoting our respective products and services (and any agents used by us and our business partners in administering such an arrangement or alliance);
anyone supplying goods or services to you in connection with a rewards program associated with the facility;
debt collecting agencies;
other financial institutions;
external payment systems operators;
any mortgage insurer used by us and any reinsurer of any such mortgage insurer;
your and our insurers or prospective insurers and their underwriters;
any person to the extent necessary, in our view in order to carry out any instruction you give to the by us;
(unless you tell us not to) other organisations (including our related bodies corporate) and their agents for the marketing of specific products and services.
In some cases, we may need to transfer your personal information overseas. If we believe that the overseas third party is not subject to privacy obligations equivalent to those which apply to us we will seek your consent to transfer the information, except where the National Privacy Principles do not require us to do so.
<h3>Your Access to your Personal Information</h3>
If at any time you wish to know what personal information we are holding about you, you are welcome to apply for your details by logging into your account [accountname.instance.zuluedm.com], phone us or use the support desk https://support.zululabs.com
You can at any time log into the subscriber console for any of our websites to view marketing data we hold and can amend or delete everything except your email address as this has mandatory for Zulu Labs to be compliant with the SPAM Act 2003 ensuring we do not contravene your wishes if you do not wish to be contacted.
Under certain circumstances, we may not be able to tell you what personal information we hold about you. This includes where:
it would have an unreasonable impact on the privacy of other individuals;
the information relates to legal proceedings with you; or
we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.
We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. If at any time you believe that personal information that we hold about you is inaccurate, incomplete or out of date, please advise us by telephoning us
<h3>Security of your Personal Information</h3>
We maintain strict procedures and standards and take all reasonable care to prevent unauthorised access to, and modification and disclosure of, your personal information. We will take all reasonable steps to protect your personal information from misuse and loss.
We also protect the security of your personal information when transmitted over the Internet. We use a Domain Name Security (DNSSEC), Secure Socket Layer (SSL) to transfer personal information between you and our web servers with relation to online payment details, and GPG encryption when we transfer data to third parties. However no data transmission over the Internet can be guaranteed as fully secure and accordingly, we cannot guarantee or warrant the security of any information you send to us using our on-line forms or products. You submit information over the Internet at your own risk. If we no longer need your information, we will destroy or de-identify it.
We adhere to the Direct Marketing Code of Conduct produced by The Australian Direct Marketing Association (ADMA) and the Direct Marketing Association LLC (DMA USA).
We will use your personal details, including your email address, to provide you with information, specific promotions and products that may be of interest to you. We also provide your details to other organisations (including our related companies) but only for specific marketing purposes.
If at any time you do not wish to receive further marketing information, you have the option to ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this by telephoning us.
We do not use your tax file number, or any other government identifier as your account, policy or application number. We will only use and disclose these numbers for the purposes required by law.
<h3>Complaints about Breaches of Privacy</h3>
If you believe that the privacy of your personal information has been compromised or is not being adequately protected, you should contact us by telephoning us. We will make every effort to resolve your complaint. We have documented breach processes and disclosure of a breach is governed by the Australian Data Breach Laws.
If we do not resolve your complaint to your satisfaction, you may apply to the Federal Privacy Commissioner to have your complaint investigated. For more information about how you may lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hotline service on 1300 363 992.
<h3>Our Internet Websites</h3>
("The Zulu Labs Websites").
When you use a link from the Zulu Labs Websites to the websites of third parties, those websites are not subject to our privacy standards. Those third parties are responsible for informing you of their own privacy policies.
Our payments providers include PayPal and, Eway Pty Ltd, operates the SSL certificate we use for online credit card payments. Please see the PayPal website https://www.paypal.com Eway web site, https://www.eway.com.au for their privacy and security policy.
If personal information about you is collected by third parties on any websites you have accessed through our website, we may also collect or have access to that information as part of our arrangement with those third parties.