Privacy policy

Last updated: July 26, 2023. This Privacy Policy is effective from August 10, 2023. For the Privacy Policy in effect before August 10, 2023, please refer to here.

 

As you may already be aware, Zuluhood is all about security. But not just the security of your Home, yourself, or your Tribe Members. We also want to protect your privacy. You have placed your trust in us by using Zuluhood, and we value that trust. That means we are committed to protecting and safeguarding any personal data you give us. We act in our customers' interest and want to be transparent about processing your personal data.

This Privacy Policy explains what information we collect, how we use it, and your rights if you want to change how we use your personal information. If you have concerns about how we use your personal information, you can contact us at privacy@zuluhood.com.

We shall keep this Privacy Policy updated and, therefore, might change it from time to time. If you care about your privacy, read it regularly, and you'll know exactly where you stand. If we make changes to the Privacy Policy which will impact you (for example, if we intend to process your personal data for purposes other than communicated in the past in this Privacy Policy), we will notify you of these changes before the new activities begin. We always indicate the date the last changes were published at the top of our Privacy Policy.

WHO ARE WE?

We are Brombul Ltd, creators and owners of Zuluhood. Our registered office is in Zagreb, Croatia, at Rudeška cesta 246. Further in this Privacy Policy, we shall refer to ourselves as "we", "us", or "our". All other capitalized terms have the meaning given to them in our Terms and Conditions.

We will:

  • always keep your personal data safe and private;

  • never sell your personal; and

  • allow you to manage your consent choices at any time.

We will collect your personal information when you use:

  • Zuluhood Web

  • Zuluhood Mobile App; or

  • any of the services you can get access to through Zuluhood.

When you share your information with us, we become what is known under data protection regulation as the 'data controller' of your personal data.

WHAT KIND OF PERSONAL DATA DO WE COLLECT?

You can't use our Zuluhood Mobile App or our Zuluhood Web without us collecting your personal data.

BASIC ACCOUNT DATA. When you first register in Zuluhood, we will ask you for your basic information: your name, surname, mobile phone number, email address and date of birth. This is the basic information we need for you to become a User (your name, surname, and mobile phone number) and to be certain of your age (date of birth). We need to check your age since you must be 18 years old to use the full scope of the Zuluhood Services, especially Services provided by Service Providers, or to act as a Watcher for another Zuluhood User. To protect your Account better (e.g., recover your Passcode) and to be able to receive information about Zuluhood we believe is important to you (e.g., change of Terms or Conditions), we need your email address as well.

Once you become a Zuluhood User, you will be able to manage your personal details. For your Home and your own profile, you will decide what information will be shared with other Users (public profile) when you interact with them. When you invite Tribe Members to your Home, we will process their personal information as well (their name, mobile phone number and age). All the information you enter in Zuluhood will be securely stored as your account data.

YOUR ADDRESS. When you add a Home in Zuluhood, we will ask you to provide the correct address of that Home. We need your Home address to be able to check the Services available for your Home and to place your Home in the right neighborhood where you can choose available Watchers (Local Watchers) or offer your services as a Local Watcher to your neighborhood. If the Alarm for your Home is activated, the address of your Home will be shared with the Watchers you have added to your Home and the Service Provider you have engaged. The address of your Home will not be visible to your Watchers in any other situation.

LOCATION DATA. Zuluhood does not track or store your phone location, but if you allow us to, we may access it even when you don't use your Zuluhood Mobile App or close it in the background. We are checking your phone's location with your permission to help you add your Home address. If you allow it in your phone settings, we'll be informed when your phone enters or leaves the area around your Home. We create a virtual boundary around your Home location and stay in touch with your device. If your phone enters this boundary, Zuluhood your phone will notify Zuluhood that you're at home. If it leaves, Zuluhood will be notified that you've gone out. You can easily turn location processing on or off in your phone settings. Keep in mind that some Zuluhood Services will only work if you allow us to use your location data. These services include notifications about an empty home, information about your Tribe being home when you check in Zuluhood, and more. The information about whether someone is home or not is only visible to Tribe Members when they open Zuluhood Mobile App and to Watchers during an Alarm. We don't save this information; it's updated only when your phone tells us about any changes.

YOUR ID DETAILS. As Zuluhood is a platform focused on providing security, we also want our Users to be secure. To ensure the safety of our platform and prevent fraud, we have implemented an identity verification process called "know-your-client" (KYC). This process confirms that you are who you claim to be. During KYC, we'll ask you to provide some identification documents like your passport or ID card, and we'll also request a selfie from you. We keep copies of these documents and your selfie securely to confirm the process if needed. Your information is stored with the utmost care in a strictly encrypted environment with limited access. Once your identity is verified, you'll receive a "Verified User" badge on your public profile. This badge signals to others that you've passed the verification and can be trusted. It's an additional layer of security for everyone on Zuluhood because other Users will know that you are genuinely who you say you are, making interactions with you safer and more secure. It is also a simple and fast method to verify your identity if you want to use the Services provided by the Service Providers. In that case, identity verification is necessary to confirm the validity of contracts between you and the Service Providers, which are accepted online, and to guarantee the identity of the person seeking highly sensitive security services.

USAGE DATA. We may keep a record of your correspondence with other Zuluhood Users and Service Providers during Service Requests or Alarms. These communication data will be stored on the Zuluhood platform and processed only when they contain information necessary to fulfil contractual obligations, legal requirements, law enforcement requests, or serve our legitimate interests. If you permit us, we may also collect data such as your contact lists, Facebook friends, or similar data from other online accounts to facilitate connections with others through Zuluhood. When you visit Zuluhood Web, we collect data to improve our services. This includes your IP address, country, date, and time of accessing our services, hardware, software, or internet browser you are using, and information about your computer's operating system, such as application versions and language settings. We also gather data on clicks and pages displayed to you. When accessing or using Zuluhood on a mobile device, we collect data that identifies your device, specific device settings and characteristics, Zuluhood mobile app crashes, and other system activities.

WHEN DO WE COLLECT PERSONAL DATA?

We collect the information you provide when you, for example:

  • fill in any forms;

  • correspond with us;

  • register to use the Zuluhood Mobile App;

  • enter your Home details or add any additional Homes;

  • invite a Tribe Member to join your Home;

  • invite a Watcher to watch your Home;

  • become a Watcher for your neighborhood (Local Watcher);

  • contact a Local Watcher in your neighborhood;

  • raise the Alarm or open Home chat;

  • check on the location of your Tribe;

  • change your subscription plan;

  • sign a contract with the Service Provider under your Zuluhood Account;

  • request Service from the Service Provider in your Zuluhood Mobile App;

  • take part in online discussions, surveys or promotions;

  • speak with a member of our customer support team;

  • visit our Zuluhood Web or use our Zuluhood Mobile App;

  • contact us for other reasons.

 

WHY DO WE COLLECT AND USE YOUR PERSONAL DATA?

We must have a valid legal basis to collect and process your personal data. We will only proceed with collecting and processing your data if a legitimate legal basis exists. Our legal basis for your data processing is listed below.

CONTRACT. We provide you services through the Zuluhood Mobile App in compliance with our Terms and Conditions, which form a contractual agreement between you and us. For you to use and benefit from our Zuluhood Services as stated in the Terms and Conditions, we need certain personal information. Without this information, we might not be able to provide our services or services offered by third parties.

LEGAL OBLIGATIONS. In some cases, we are obliged to collect and store your personal information by law to comply with legal and law enforcement requests (for example, for accounting purposes).

LEGITIMATE INTEREST. We will rely on this legal basis only when we have a legitimate reason to collect and use your personal data. This reason is always balanced against your right to privacy before the beginning of the data processing itself (for example, for improving our services).

YOUR CONSENT. We process your data on this basis only when you have explicitly agreed to and only in certain situations (for example, when you add your picture to your profile or allow us to process your location data).

VITAL INTEREST. We will rely on this legal basis only when it is necessary to protect your or another person's vital interests, which we expect to be in extreme, rare cases.

If you wish to object to specific processing but cannot opt-out through your account settings, feel free to contact us at privacy@zuluhood.com. We will be happy to assist you with your request.

 

HOW DO WE USE YOUR PERSONAL DATA?

We can summarize the reasons we collect and use your personal data in just 4 points:

  • to be able to provide our services in the best way possible;

  • to be able to tell you about products and services you may be interested in;

  • to further improve our services;

  • to meet our legal obligations.

TO PROVIDE OUR SERVICES
Providing your personal data to Zuluhood is voluntary. However, we cannot provide you with our services without collecting and processing certain personal data. Furthermore, there is not just one but more types of services provided through Zuluhood. Some of them request even more personal data than initially collected. Please be aware of that before accepting our Terms and Conditions and using our services.

For instance, you cannot set up your Home and manage your Home's security in the Zuluhood Mobile App if we do not collect your name and surname, age and contact details. Whenever you log in to the Zuluhood Platform, we will use your personal data to identify you as our User. The address is essential for us to accurately position your Home in the correct neighborhood or display Services available for a specific Home. Additionally, Service Providers cannot respond to your Service Requests, and Watchers cannot assist you during Alarms if we don't provide them with information about who you are and where your Home is located.

When you are part of a Tribe, your phone's location data may be processed in the following cases:

  • To notify the User who manages your Tribe (Home Chief) if your Home is empty.

  • To share your status of whether you are at home or not within the Tribe or when Alarms and Home chat are activated.

Please note that such location data will be processed only if you have granted permission in your phone settings (given us your consent). If you are a Tribe Member above 18, we will share your name, surname, and contact information with the Services Provider in a Service Request for your Home. That is because you are considered an additional contact person who can confirm the Alarm or something else important in case of necessity.

If you want to use Services for your Home, we may process your personal information to check your identity (as part of our KYC process). By conducting such a process, we check whether you are who you claim to be before you enter into an agreement with the Service Provider.

Users interact in Zuluhood with their public profiles, which can be modified anytime. However, your name and your mobile phone number are visible to Watchers and Tribe Members you have invited to your Home in Zuluhood. The same goes the other way: if you are invited to another User's Home as a Watcher or a Tribe Member, once you accept User's invitation, your real name and mobile phone number will be visible to the User who invited you. We share this information because we want you, and all the Users you interact with, to be as safe as possible when using Zuluhood. We encourage you to use this information and get to know the other User better before you decide that you can trust him with additional personal data and the safety of your Home. If you change your mind about a specific User, you can always remove him from your Home.

We share your Home address with your selected Watchers only when the Alarm is raised for your Home. If you consent to process your phone's location, Watchers checking the Alarm details may see if you're at home and in potential danger during the Alarm.

When you make a Service Request, we share your personal information (name, surname, Home address, and comments) with the Service Provider you've chosen. This allows them to provide their Services effectively.

We also use your personal information to comply with our legal obligations under Zuluhood's Terms and Conditions. This includes processing payments and invoicing for the Services you purchase in your Zuluhood Mobile App. Additionally, we may be required to provide additional information as mandated by the law, such as in court proceedings.

Interactions with other Users in the chat are not stored after closing the chat, whether it's an Alarm or Home Chat. However, in some cases, we may access and process chat communication for a specific period based on our legitimate interest solely to detect, verify, or prevent malicious activities or to fulfill our legal obligations.

We also use your personal information when you contact our customer support, to send you invoices and relevant information regarding your use of Zuluhood Services and to notify you about any changes in our Terms and Conditions and Privacy policy.

FOR MARKETING PURPOSES
We are constantly developing Zuluhood and doing our best to expand our products and services. For that reason, we would like to keep you updated about our work. When we believe that we have something relevant to share with you regarding Zuluhood Services, we will contact you at your email address to inform you about goods and services we offer that are similar to those you have already used or asked us about, or which we think you might be interested in. For this purpose, we may use the data you have provided to us, especially your email address, information about your device, and your country of residence. We use this information based on our legitimate interest to sell, offer and promote our products and services. If you do not agree with the processing of your personal data for this purpose, you can always opt-out by sending us an email at privacy@zuluhood.com, and we will make sure to address your concerns and fulfill your requests.

TO IMPROVE OUR PRODUCTS AND SERVICES
We analyze how Users use the Zuluhood Mobile App to improve existing services and develop new ones. Generally, this data is entirely anonymized and used only for statistics. However, there may be specific cases when we need to process the personal data of our Users to improve our products and services, like when we need to perform detailed data analysis, research, troubleshooting, and testing. We use this information based on our legitimate interest to improve our products and our services, and our business in general.

TO MEET OUR LEGAL OBLIGATIONS
Finally, in certain cases, we may need to use your personal information to meet our legal obligations. This includes handling and resolving legal disputes and adhering to lawful requests from law enforcement. The same principles apply when enforcing Zuluhood's Terms and Conditions or the Service Terms of the Service Provider you have selected.

 

DO WE MAKE ANY AUTOMATED DECISIONS ABOUT YOU?

We make automated decisions about you only during the identity verification process (KYC process). This method is used to verify your identity before entering into a legal contract with the Service Provider and to enable secure interactions among Users. The process involves comparing the image from your official document (ID card or passport) with a selfie taken at the moment of verification. The compatibility of these images is determined automatically. Zuluhood also automatically compares the name and surname from your official document with the name and surname you provided on your Zuluhood Account. Therefore, for identity verification, we automatically check if your photo from the official document matches the selfie and if your name and surname match as well. Before you accept the Service Terms of the selected Service Provider, your identity needs to be verified to ensure the validity of the online contract. However, it is your choice to undergo the described identity verification process implemented in Zuluhood. You can always withdraw your consent or choose to avoid automated decision-making processes. If any of these cases arise, don't hesitate to contact us, and we'll help you resolve your request.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

In certain situations, we share your personal data with third parties. The categories of third parties are listed below.

THE SERVICE PROVIDERS. To receive a Service you request through the Zuluhood Mobile App, we share relevant details with the Service Provider you choose. This may include your name, Home address, contact details, the names and contact information of adult Tribe Members added to your Home and any comments you provide for the Service Request. However, we do not disclose the personal data of Tribe Members who are minors or your Watchers, and we do not share your chat correspondence within the Zuluhood mobile app. In certain cases, depending on the Service type and your Zuluhood Mobile App settings, we may forward additional information to the Service Provider to ensure an optimal response to your Service Request. This information, such as the number of people present at your Home during an Alarm, or the phone number of the Tribe Member who raised the Alarm is shared only if you have specified it in your Zuluhood Mobile App settings. You must provide consent to access your phone location and allow Tribe Members to raise the Alarm for your Home to enable this sharing. In the event of a Service-related dispute, we may share information about the entire interaction process with the Service Provider to help resolve the issue. This may include providing them with a copy of your purchasing history and Service Request details as evidence that the Service was ordered through Zuluhood.

THIRD-PARTY SERVICE PROVIDERS. We use several service providers for support services in Zuluhood, including AWS cloud services, ID document scanning and image matching, third-party payment processors, invoicing services, and third-party customer relationship management (CRM) tools. All service providers are obligated to safeguard your personal data adequately.

COMPETENT AUTHORITIES. We disclose personal data to law enforcement insofar as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts and fraud or if we are otherwise legally obliged to do so. We may need to further disclose personal data to competent authorities to protect and defend our rights or properties.

We may transfer your personal data to countries with different data protection laws than those in the European Union. However, we only transfer data to recipients who provide an adequate level of data protection, as required by European regulations.

 

HOW DO WE PROCESS YOUR COMMUNICATIONS WITHIN ZULUHOOD APP?

Zuluhood allows you to communicate with other Users, such as your Tribe Members or Watchers, through chat interfaces when the Alarm or Home chat is initiated. Typically, we do not access or retain this communication after you close the chat for your Home. However, in certain cases, we may access and use automated systems to review, scan, and analyze the communication for security purposes, fraud prevention, compliance with legal and regulatory requirements, and investigations of potential misconduct or for providing customer or technical support. We reserve the right to block the delivery of or review communications that we believe, at our sole discretion, may contain malicious content, spam, or pose a risk to you or other Zuluhood Users. We do not control or have access to the communication between you and other Users or Service Providers if they communicate with you through phone calls or other communication channels that Zuluhood does not control.

 

WHAT SECURITY AND RETENTION PROCEDURES AND TERMS HAVE WE IMPLEMENTED TO SAFEGUARD YOUR PERSONAL DATA?

We take data security seriously and have implemented strong measures to protect your personal information. This includes using certified systems with restricted access, encrypting data during transfer and storage, and conducting regular security checks. All your data is stored securely within data centers that are fully certified with ISO standards. Only authorized personnel have access to the system. Your Passcode is always encrypted and never shared with us. Therefore, we advise you to enter a valid email address into your Zuluhood Account, as otherwise, you won't be able to change your Passcode or unlock your Account.

If we use automated means to process personal data that significantly affects you, we will implement measures to safeguard your rights and freedoms.

We ensure that our safety measures remain in place throughout the entire retention period. When determining how long we keep personal data, we consider applicable laws, your interests, recommendations from supervisory authorities, and other relevant factors.

We retain your personal data as long as needed to provide our services, comply with laws, resolve disputes, prevent fraud, and conduct our business, all following this Privacy Policy.

Sometimes, we may need to keep personal data longer to comply with legal requirements, provide evidence in court or other proceedings, or meet operational needs. Deleting data prematurely could lead to non-compliance, legal challenges, or operational difficulties.

Once personal data is no longer needed, we will promptly and securely delete or destroy it, as permitted by applicable law.

 

HOW DO WE TREAT THE PERSONAL DATA OF CHILDREN?

To create a Zuluhood Account, request Services, become a Watcher, or invite Tribe Members or Watchers to your Home, you must be at least 18 years old. Children under 18 can become Zuluhood Users only if invited as Tribe Members by adult registered Zuluhood Users. After being selected as a Tribe Member, a child will receive an invitation to download the Zuluhood Mobile App and register. For children under 18, using Zuluhood Services requires parental or legal guardian consent. Therefore, when inviting a child to join the Tribe, ensure you have valid consent from the child's parent or legal guardian. We advise you to review and approve the child's public profile in the app, as it may be visible to other Tribe Members and Watchers. If we discover that we process information of a child under 18 without valid consent from the child's parent or legal guardian, we reserve the right to delete it.

 

HOW CAN YOU CONTROL THE PERSONAL DATA YOU HAVE GIVEN TO US?

We want you to be in control of the way we use your personal data. In this connection, you have the following rights:

  • the right of access (you can request access to the personal data we process about you and ask us for a copy of such personal data);

  • the right to rectification (you can inform us of any changes to your personal data, or you can ask us to correct any of the personal data we hold about you, or you can make such changes yourself, if applicable);

  • the right to erasure (in certain situations, you can ask us to erase the personal data we hold about you);

  • the right to restrict (in certain situations, you can block or restrict the processing of personal data);

  • the right to object (in certain situations, you can object to ways in which we use your personal data);

  • the right to data portability (in certain situations, you can also ask us to send the personal data you have given us to a third party).

When we are using your personal data based on your consent, you are entitled to withdraw that consent at any time, subject to applicable law. Withdrawal of your consent does not affect the validity of the data processing we carried out based on that consent before the withdrawal. Moreover, where we process your personal data based on legitimate or public interest, you have the right to object at any time to such use of your personal data, subject to applicable law.

We rely on you to ensure that your personal data is complete, accurate and currently correct in your Zuluhood Mobile App, as we will always provide you with the option to add, update or remove information we have about you.

If you have any requests or complaints regarding this Privacy Policy or questions related to exercising your rights, don't hesitate to contact us at privacy@zuluhood.com. You may also contact your local data protection authority (data protection agency).

HOW TO CONTACT US?

The owner and creator of Zuluhood, Brombul Ltd, controls the processing of personal data as described in this Privacy Policy. Brombul Ltd is a private limited liability company incorporated under the laws of the Republic of Croatia. If you have any questions about this Privacy Policy or our processing of your personal data, please contact us at privacy@zuluhood.com, and we will respond to you as soon as possible.