Privacy policy
Last modified: 19.04.2021.
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 we want to be transparent about the processing of 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 our data protection officer 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 that will have an impact on you (for example, if we intend to process your personal data for other purposes 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. We are a team of professionals coming from IT security and physical security industries, committed to helping people to protect their homes and families with the help of the Zuluhood Platform. 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 information safe and private;
- never sell your information; and
- allow you to manage and review 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 choose to share your information with us, we become what is known under data protection regulation as the 'data controller' of your personal information which you provided us with, in order to provide our services to you.
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, e-mail address and date of birth. This is the basic information we need for you to become a User (your name and 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 be able 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 e-mail 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 you want to protect in Zuluhood, we will ask you to provide the correct address of that Home. Your Home address is important to place you in the right neighbourhood so you can choose local available Watchers (Local Watchers), check available professional Services or offer your services as a Local Watcher to the local community. If you raise the Service Request or Community Request in Zuluhood Mobile App, i.e., alarm for your Home, your Home address will be shared with Watchers or Service Providers you’ve selected. Your Home address will not be shared with 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 need to check your phone location to position your home in the right neighbourhood or position you on the local map if you decide to become a Local Watcher. We are also informed when your phone enters or leaves the defined perimeter around your Home if you allowed us to. We process this information by setting a virtual perimeter around your home location and communicating with your device. If your phone enters your home perimeter, Zuluhood will be informed that you are home. If your phone leaves the perimeter, we will be informed that you have left. That is why location processing can easily be enabled and disables through the settings of your phone. However, please note that some Zuluhood Services will only be available if you allow us to process your location data, such as: notification if your Home is empty, information if your Tribe is at home when you check your Home in Zuluhood, information if you Tribe is at home in Zuluchat or alarm (on Service or Community Requests).
Your ID details. As Zuluhood is a platform focused on providing security, we also want our Users to be secure. To be able to prevent any fraudulent or illegal activities and deter any malicious use of our Zuluhood Mobile App, we need to be certain who our Users are. That is why we may ask you to go through our know-your-client (KYC) process (the process of how we check if our Users are genuinely who they claim to be). For that purpose, we process your identification documents (for example, your passport or ID card), keep copies of the documents you have provided for identification purposes, your picture and personal description (if you provide one) and any other information you provide in order to prove you are who you claim to be and to be eligible to use our services. KYC process is mandatory if you want to use Services provided by the Service Providers. If you do not agree to perform and pass the KYC Identity Verification or cannot pass it, you won’t be able to use Services via Zuluhood Platform. Once your identity is verified, you will receive the status of the “Verified User” visible in your public profile. With that information, Users with whom you interact in Zuluhood will also know that you can be trusted.
Usage data. When you purchase a Service, we shall keep records of your correspondence with other Zuluhood Users and Service Provider during Service Requests. We will store these communication data in Zuluhood Platform and process them only when they contain information important to us to be able to fulfil our contractual obligations, meet our legal obligations, meet law enforcement requests or pursue our legitimate interest. If you allow us to, we shall collect information such as your contact lists, or friends lists from Facebook or similar information from other online accounts to make it easier for you to connect with others through Zuluhood. When you visit Zuluhood Web we also collect certain information to be able to improve our services. This includes your IP address, your country, the date and time you accessed our services, the hardware, software or internet browser you use and information about your computer’s operating system, like application versions and your language settings. We also collect information about clicks and which pages have been shown to you. When you are accessing or using Zuluhood on a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, Zuluhood Mobile App crashes and other system activity.
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 community available Watcher for your neighbourhood (Local Watcher);
- contact a community available Watcher (Local Watcher) in your neighbourhood;
- raise an alarm or open Zuluchat, i.e., make Service or Community Request, or use any of Zuluhood Services;
- check on the location of your Tribe;
- change your subscription plan;
- sign a contract with Service Provider available via Zuluhood;
- request Service available from selected Service Provider;
- 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?
To collect and process your personal data we must have a valid legal basis. We will only collect and process your personal data if we have a legal basis to do so. Our legal basis for your data processing is listed below.
Contract. We provide you services through Zuluhood Mobile App based on, and in accordance with, our Terms and Conditions. Our Terms and Conditions are a contract concluded between you and us. To keep you as our User and provide you with our Zuluhood Services, as agreed in the Terms and Conditions, we need certain personal information without which we are not even able to provide our or third-party services.
Legal obligations. In some cases, we are obliged to collect and store your personal information by law, in order 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 that we collect your information. We will base process your personal data on this legal basis only in certain situations (for example, when you add your picture, verify your profile, or allow us to process your location data)
Vital interest. We will base the processing when it is necessary to protect your vital interests or the vital interests of another person. We will base the processing of your personal data on this legal basis only in extreme, rare cases.
Public interest. We will usually not base processing of your personal data on this legal basis. However, we cannot predict all future situations which may be extraordinary and request processing based on this legal basis. For that reason, we wanted you to be aware of this legal basis as well.
If you wish to object to certain processing but you can’t opt-out of this processing by yourself (for example, in your account settings), please contact privacy@zuluhood.com.
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. Therefore, if you want to use our services you need to provide us with 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 requesting 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, age and contact details. Whenever you log in to the Zuluhood Platform we will use your personal data to be able to identify you as our User. The address of your Home(s) will be used to locate you in the correct neighbourhood. Also, Watchers or professional Service Providers cannot answer your Service or Community Request if we do not let them know where your Home is.
If you are a member of a Tribe, your location data might be processed in the following cases: to notify the User who manages your Tribe (Home Chief) if your Home is empty, to share the information if you are at home or not with other members of your Tribe when they view your Home in Zuluhood, and when the Service or Community Requests (the alarm or Zuluchat) are activated. Your location data will be processed in these cases only if you allow it in your phone settings.
If you want to use professional Services available in your region, we will 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 information and the safety of your Home. If you change your mind about a specific User, you can always remove them from your Home.
The only time we share your Home address with your selected Watchers is when you allow us to by raising the alarm or when you make a Service Request. Your location (location of your phone), if processed in Zuluhood, is not shared with your Watchers.
If you request any professional Service, we shall forward your personal information (name, surname and your Home address) to Service Provider you have chosen, for them to be able to provide their services.
When you are already registered as a Zuluhood User, we use your personal information to meet our obligations arising from Zuluhood’s Terms and Conditions. That also refers to the process of payment and invoicing. To carry out those processes and process transactions you make, we need to process your personal data. For more details on methods of payment, please see our Terms and Conditions.
Your personal data incorporated in your interaction and communication with other Users while alarm or Service Request is activated will be saved for security reasons (to prevent any malicious activity).
We also use your personal data to give you details of our products and services and to help us develop new products and services.
We also use your personal information to contact you by phone and provide you with customer support services, but only when you provide us with such information. We may record these calls, but only for internal training and quality control purposes.
Marketing
We are constantly developing Zuluhood and doing our best to expand the range of products and services we offer. 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 e-mail 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;
- measure or understand the effectiveness of our advertising and provide relevant advertising to you.
For this purpose, we might use the data you have provided us with, especially your e-mail address, information from your device, location information and information we collected from third parties. We use this information based on our legitimate interest to sell, provide and promote our products and services. In case you don’t agree with the processing of your personal data for this purpose, you can always opt-out of this kind of process of your personal data. You can do it simply by sending an email to our data protection officer at privacy@zuluhood.com and we will make sure your questions are answered and your requests are fulfilled.
Improvement of our products and services
Sometimes we will use your personal data, as the data of our Users, to improve our and third-party products and services we offer through Zuluhood. To do that we can use your personal data to manage and improve our Zuluhood Mobile App and Zuluhood Web (including data analysis, research, troubleshooting, testing, statistical and survey purposes). We use this information based on our legitimate interest to improve our products and our services, and our business in general. We may also record calls between you and our customer support service to train our staff and improve their abilities, but also to control the quality of our services.
To meet our legal obligations
Finally, in certain cases, we may need to use your personal information for regulatory investigations and compliance. We may also use your personal information to handle and resolve legal disputes and to comply with lawful requests from law enforcement. This shall also be the case when enforcing the Zuluhood’s Terms and Conditions or terms and conditions of the Service Provider you have chosen to provide Services to you.
Do we make any automated decisions about you?
We make automated decisions about you only when conducting the KYC (know your customer) verification method. We have implemented this method to verify your identity and ensure safe use of Zuluhood, that is to protect Users from possible frauds, thefts and assaults. We also use it to verify your identity during the contract signing process with Service Provider.
The process consists of comparing the image of the User from his/her official document (ID or passport) with selfie taken just before the moment of the process (comparison) itself. The compatibility of these images is determined automatically. If you pass this verification (i.e., your image from your official document is compatible with the selfie taken), you can use certain services, as described in the Terms and Conditions.
We will conduct the KYC verification method only if you previously give us your explicit consent. You can always withdraw given consent in accordance with this Privacy Policy.
If you don’t want to be subject to an automated decision-making process and give your consent to us to conduct the KYC verification method, you can always send us an image of your official document and your selfie to the following address: privacy@zuluhood.com. In that case, our staff will compare sent images and grant you the usage of certain services (if they verify your identification). In that case, we will also need your consent to process your images.
Do we share your personal data with third parties?
In certain circumstances, we will share your personal data with third parties. We share your personal data with the following categories of third parties:
The Service Provider you requested. This one is pretty crucial for what we do! For you to receive a professional Service you can request through Zuluhood Mobile App, we transfer relevant details to the Service Provider you choose. Depending on the Service and the Service Provider of your choice, this can include your name, address of your Home and your contact details. Personal data of your Tribe Members or your Watchers, as well as your correspondence in Zuluhood mobile app will not be disclosed. In certain cases, depending on the type of Service and your Zuluhood Mobile App settings, and in order for Service Provider to deliver the optimal response to your Service Request, we may also forward information about the number of persons who might be at the location of your Home (i.e., when you request an urgent response) or phone number of the Tribe member who has initiated the Service Request on your behalf. However, we will not share the personal details of your Tribe members (their phone numbers) with Service Providers unless you allow us to with your choices in Zuluhood Mobile App (i.e., allow a Tribe Member to initiate Service Request) or provide it directly to Service Provider by yourself. In case of a Service-related dispute, we may provide the Service Provider with information about the whole interaction process as needed to handle the dispute. This may include a copy of your purchasing history and Service Request, as proof that Service was ordered through Zuluhood.
Third-party service providers. We use service providers to support us in providing our services. These service providers provide support services such as:
- AWS cloud platform (Zuluhood platform is processed on AWS cloud);
- identity verification as part of the KYC process;
- fraud detection and prevention services, including anti-fraud screening service or screening for malicious activities;
- payment services (We use third parties to process payments or provide billing collection services. We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes);
- CRM providers (We use a third-party CRM system).
All service providers are required to continue to adequately safeguard your personal data.
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.
The transmission of personal data as described in this Privacy Policy may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. As required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements by sending us an e-mail to the following address: privacy@zuluhood.com.
How do we process your communications within Zuluhood app?
Zuluhood offers you to communicate with other Zuluhood Users, specifically your Tribe Members or Watchers. Depending on your location, you may also be able to receive information from the Service Provider regarding the Service Request you made.
We may access communications and may use automated systems to review, scan, and analyse communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you, or other Zuluhood Users. Please note that all communications sent or received through Zuluhood Platform during the alarm or Service Request will be stored by Zuluhood, in accordance with this Privacy Policy. However, Service Providers may choose to communicate with you directly via mobile phone or other channels that Zuluhood does not control.
What security and retention procedures and terms have we put in place to safeguard your personal data?
We observe reasonable procedures to prevent unauthorized access to, and the misuse of, personal data. We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on the servers we use. Only authorized personnel are permitted to access personal data during their work. Your password, however, will always be encrypted and is never shared with us. For that reason, we advise you to add a valid e-mail address to your Zuluhood profile, as we won’t be able to help you recover your Zuluhood account without it.
If we use automated means to process personal data which produces legal effects or significantly affects you, we will implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention, as previously described for conduction of the KYC verification method.
We will use the implemented safety mechanisms for the entire duration of the retention period as well. When determining the retention period of personal data, we will consider applicable laws and regulations, your interests, recommendations of supervisory authorities and other circumstances relevant to determine appropriate retention time for individual categories of personal data. In each new processing, we will consider whether the proposed retention period is necessary to achieve a particular processing purpose. When storing personal data, we take care that each processing is fair, proportionate and in accordance with the purposes for which personal data is collected.
We retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you (including maintaining your Zuluhood Account (if created)), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Policy.
In certain circumstances, it may be necessary to keep personal data for a longer period of time in order to comply with legal and other regulations, for the purpose of proving in court or other proceedings, or for the operational needs of Zuluhood. Premature deletion or destruction of personal data could sometimes result in non-compliance with applicable regulations, inability to defend oneself in court or other proceedings, operational difficulties, or damages.
Personal data that are no longer needed are deleted or destroyed in a timely manner (if permitted by applicable law).
How do we treat the personal data of children?
To create a Zuluhood Account, to become a Watcher or a User who founds his/her Tribe, you must be at least 18 years old. A child (a person under the age of 18) may become a Zuluhood User only by being selected as a Tribe Member from the contact list of an adult registered Zuluhood User. After such a User selects the child as a Tribe Member, Zuluhood will send an invitation to the child’s phone number to download Zuluhood Mobile App and register as a Tribe Member. Children can only use our Zuluhood Mobile App in the role of Tribe Member.
For children (persons younger than 18 years) the use of any of our Zuluhood Services is only allowed with the consent of a parent or a legal guardian. Therefore, when you are inviting a child to your Zuluhood Account in the role of Tribe Member, make sure that you can prove that you are the child’s parent or a legal guardian or have a valid consent of the child’s parent or a legal guardian. We invite you to control and approve the child’s public profile in Zuluhood Mobile App, as you will be able to check it in your Home Tribe details since the child’s public profile could be shared with your other Tribe Members and your Watchers.
If we become aware that we process information of a child under 18 years old without the valid consent of a 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 but, as explained below, you may be able to make such changes yourself);
- 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 the 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 interest or the 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 the exercise of your rights, please contact us by contacting our Data Protection Officer at privacy@zuluhood.com. You may also contact your local data protection authority.
How to contact us?
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 Croatia and has its offices at Rudeška cesta 246, 10000 Zagreb, Croatia. If you have any questions about this Privacy Policy or about our processing of your personal data, please contact our data protection officer via privacy@zuluhood.com and we will get right back to you.
ZULUHOOD PRIVACY POLICY
Last modified: 19.04.2021.
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 we want to be transparent about the processing of 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 our data protection officer 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 that will have an impact on you (for example, if we intend to process your personal data for other purposes 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. We are a team of professionals coming from IT security and physical security industries, committed to helping people to protect their homes and families with the help of the Zuluhood Platform. 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 information safe and private;
- never sell your information; and
- allow you to manage and review 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 choose to share your information with us, we become what is known under data protection regulation as the 'data controller' of your personal information which you provided us with, in order to provide our services to you.
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, e-mail address and date of birth. This is the basic information we need for you to become a User (your name and 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 be able 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 e-mail 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 you want to protect in Zuluhood, we will ask you to provide the correct address of that Home. Your Home address is important to place you in the right neighbourhood so you can choose local available Watchers (Local Watchers), check available professional Services or offer your services as a Local Watcher to the local community. If you raise the Service Request or Community Request in Zuluhood Mobile App, i.e., alarm for your Home, your Home address will be shared with Watchers or Service Providers you’ve selected. Your Home address will not be shared with 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 need to check your phone location to position your home in the right neighbourhood or position you on the local map if you decide to become a Local Watcher. We are also informed when your phone enters or leaves the defined perimeter around your Home if you allowed us to. We process this information by setting a virtual perimeter around your home location and communicating with your device. If your phone enters your home perimeter, Zuluhood will be informed that you are home. If your phone leaves the perimeter, we will be informed that you have left. That is why location processing can easily be enabled and disables through the settings of your phone. However, please note that some Zuluhood Services will only be available if you allow us to process your location data, such as: notification if your Home is empty, information if your Tribe is at home when you check your Home in Zuluhood, information if you Tribe is at home in Zuluchat or alarm (on Service or Community Requests).
Your ID details. As Zuluhood is a platform focused on providing security, we also want our Users to be secure. To be able to prevent any fraudulent or illegal activities and deter any malicious use of our Zuluhood Mobile App, we need to be certain who our Users are. That is why we may ask you to go through our know-your-client (KYC) process (the process of how we check if our Users are genuinely who they claim to be). For that purpose, we process your identification documents (for example, your passport or ID card), keep copies of the documents you have provided for identification purposes, your picture and personal description (if you provide one) and any other information you provide in order to prove you are who you claim to be and to be eligible to use our services. KYC process is mandatory if you want to use Services provided by the Service Providers. If you do not agree to perform and pass the KYC Identity Verification or cannot pass it, you won’t be able to use Services via Zuluhood Platform. Once your identity is verified, you will receive the status of the “Verified User” visible in your public profile. With that information, Users with whom you interact in Zuluhood will also know that you can be trusted.
Usage data. When you purchase a Service, we shall keep records of your correspondence with other Zuluhood Users and Service Provider during Service Requests. We will store these communication data in Zuluhood Platform and process them only when they contain information important to us to be able to fulfil our contractual obligations, meet our legal obligations, meet law enforcement requests or pursue our legitimate interest. If you allow us to, we shall collect information such as your contact lists, or friends lists from Facebook or similar information from other online accounts to make it easier for you to connect with others through Zuluhood. When you visit Zuluhood Web we also collect certain information to be able to improve our services. This includes your IP address, your country, the date and time you accessed our services, the hardware, software or internet browser you use and information about your computer’s operating system, like application versions and your language settings. We also collect information about clicks and which pages have been shown to you. When you are accessing or using Zuluhood on a mobile device, we collect data that identifies your mobile device, device-specific settings and characteristics, Zuluhood Mobile App crashes and other system activity.
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 community available Watcher for your neighbourhood (Local Watcher);
- contact a community available Watcher (Local Watcher) in your neighbourhood;
- raise an alarm or open Zuluchat, i.e., make Service or Community Request, or use any of Zuluhood Services;
- check on the location of your Tribe;
- change your subscription plan;
- sign a contract with Service Provider available via Zuluhood;
- request Service available from selected Service Provider;
- 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?
To collect and process your personal data we must have a valid legal basis. We will only collect and process your personal data if we have a legal basis to do so. Our legal basis for your data processing is listed below.
Contract. We provide you services through Zuluhood Mobile App based on, and in accordance with, our Terms and Conditions. Our Terms and Conditions are a contract concluded between you and us. To keep you as our User and provide you with our Zuluhood Services, as agreed in the Terms and Conditions, we need certain personal information without which we are not even able to provide our or third-party services.
Legal obligations. In some cases, we are obliged to collect and store your personal information by law, in order 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 that we collect your information. We will base process your personal data on this legal basis only in certain situations (for example, when you add your picture, verify your profile, or allow us to process your location data)
Vital interest. We will base the processing when it is necessary to protect your vital interests or the vital interests of another person. We will base the processing of your personal data on this legal basis only in extreme, rare cases.
Public interest. We will usually not base processing of your personal data on this legal basis. However, we cannot predict all future situations which may be extraordinary and request processing based on this legal basis. For that reason, we wanted you to be aware of this legal basis as well.
If you wish to object to certain processing but you can’t opt-out of this processing by yourself (for example, in your account settings), please contact privacy@zuluhood.com.
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. Therefore, if you want to use our services you need to provide us with 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 requesting 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, age and contact details. Whenever you log in to the Zuluhood Platform we will use your personal data to be able to identify you as our User. The address of your Home(s) will be used to locate you in the correct neighbourhood. Also, Watchers or professional Service Providers cannot answer your Service or Community Request if we do not let them know where your Home is.
If you are a member of a Tribe, your location data might be processed in the following cases: to notify the User who manages your Tribe (Home Chief) if your Home is empty, to share the information if you are at home or not with other members of your Tribe when they view your Home in Zuluhood, and when the Service or Community Requests (the alarm or Zuluchat) are activated. Your location data will be processed in these cases only if you allow it in your phone settings.
If you want to use professional Services available in your region, we will 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 information and the safety of your Home. If you change your mind about a specific User, you can always remove them from your Home.
The only time we share your Home address with your selected Watchers is when you allow us to by raising the alarm or when you make a Service Request. Your location (location of your phone), if processed in Zuluhood, is not shared with your Watchers.
If you request any professional Service, we shall forward your personal information (name, surname and your Home address) to Service Provider you have chosen, for them to be able to provide their services.
When you are already registered as a Zuluhood User, we use your personal information to meet our obligations arising from Zuluhood’s Terms and Conditions. That also refers to the process of payment and invoicing. To carry out those processes and process transactions you make, we need to process your personal data. For more details on methods of payment, please see our Terms and Conditions.
Your personal data incorporated in your interaction and communication with other Users while alarm or Service Request is activated will be saved for security reasons (to prevent any malicious activity).
We also use your personal data to give you details of our products and services and to help us develop new products and services.
We also use your personal information to contact you by phone and provide you with customer support services, but only when you provide us with such information. We may record these calls, but only for internal training and quality control purposes.
Marketing
We are constantly developing Zuluhood and doing our best to expand the range of products and services we offer. 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 e-mail 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;
- measure or understand the effectiveness of our advertising and provide relevant advertising to you.
For this purpose, we might use the data you have provided us with, especially your e-mail address, information from your device, location information and information we collected from third parties. We use this information based on our legitimate interest to sell, provide and promote our products and services. In case you don’t agree with the processing of your personal data for this purpose, you can always opt-out of this kind of process of your personal data. You can do it simply by sending an email to our data protection officer at privacy@zuluhood.com and we will make sure your questions are answered and your requests are fulfilled.
Improvement of our products and services
Sometimes we will use your personal data, as the data of our Users, to improve our and third-party products and services we offer through Zuluhood. To do that we can use your personal data to manage and improve our Zuluhood Mobile App and Zuluhood Web (including data analysis, research, troubleshooting, testing, statistical and survey purposes). We use this information based on our legitimate interest to improve our products and our services, and our business in general. We may also record calls between you and our customer support service to train our staff and improve their abilities, but also to control the quality of our services.
To meet our legal obligations
Finally, in certain cases, we may need to use your personal information for regulatory investigations and compliance. We may also use your personal information to handle and resolve legal disputes and to comply with lawful requests from law enforcement. This shall also be the case when enforcing the Zuluhood’s Terms and Conditions or terms and conditions of the Service Provider you have chosen to provide Services to you.
Do we make any automated decisions about you?
We make automated decisions about you only when conducting the KYC (know your customer) verification method. We have implemented this method to verify your identity and ensure safe use of Zuluhood, that is to protect Users from possible frauds, thefts and assaults. We also use it to verify your identity during the contract signing process with Service Provider.
The process consists of comparing the image of the User from his/her official document (ID or passport) with selfie taken just before the moment of the process (comparison) itself. The compatibility of these images is determined automatically. If you pass this verification (i.e., your image from your official document is compatible with the selfie taken), you can use certain services, as described in the Terms and Conditions.
We will conduct the KYC verification method only if you previously give us your explicit consent. You can always withdraw given consent in accordance with this Privacy Policy.
If you don’t want to be subject to an automated decision-making process and give your consent to us to conduct the KYC verification method, you can always send us an image of your official document and your selfie to the following address: privacy@zuluhood.com. In that case, our staff will compare sent images and grant you the usage of certain services (if they verify your identification). In that case, we will also need your consent to process your images.
Do we share your personal data with third parties?
In certain circumstances, we will share your personal data with third parties. We share your personal data with the following categories of third parties:
The Service Provider you requested. This one is pretty crucial for what we do! For you to receive a professional Service you can request through Zuluhood Mobile App, we transfer relevant details to the Service Provider you choose. Depending on the Service and the Service Provider of your choice, this can include your name, address of your Home and your contact details. Personal data of your Tribe Members or your Watchers, as well as your correspondence in Zuluhood mobile app will not be disclosed. In certain cases, depending on the type of Service and your Zuluhood Mobile App settings, and in order for Service Provider to deliver the optimal response to your Service Request, we may also forward information about the number of persons who might be at the location of your Home (i.e., when you request an urgent response) or phone number of the Tribe member who has initiated the Service Request on your behalf. However, we will not share the personal details of your Tribe members (their phone numbers) with Service Providers unless you allow us to with your choices in Zuluhood Mobile App (i.e., allow a Tribe Member to initiate Service Request) or provide it directly to Service Provider by yourself. In case of a Service-related dispute, we may provide the Service Provider with information about the whole interaction process as needed to handle the dispute. This may include a copy of your purchasing history and Service Request, as proof that Service was ordered through Zuluhood.
Third-party service providers. We use service providers to support us in providing our services. These service providers provide support services such as:
- AWS cloud platform (Zuluhood platform is processed on AWS cloud);
- identity verification as part of the KYC process;
- fraud detection and prevention services, including anti-fraud screening service or screening for malicious activities;
- payment services (We use third parties to process payments or provide billing collection services. We may share information with relevant financial institutions, if we consider it strictly necessary for fraud detection and prevention purposes);
- CRM providers (We use a third-party CRM system).
All service providers are required to continue to adequately safeguard your personal data.
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.
The transmission of personal data as described in this Privacy Policy may include overseas transfers of personal data to countries whose data protection laws are not as comprehensive as those of the countries within the European Union. As required by European law, we shall only transfer personal data to recipients offering an adequate level of data protection. In these situations, as may be required, we make contractual arrangements to ensure that your personal data is still protected in line with European standards. You can ask us to see a copy of these contractual agreements by sending us an e-mail to the following address: privacy@zuluhood.com.
How do we process your communications within Zuluhood app?
Zuluhood offers you to communicate with other Zuluhood Users, specifically your Tribe Members or Watchers. Depending on your location, you may also be able to receive information from the Service Provider regarding the Service Request you made.
We may access communications and may use automated systems to review, scan, and analyse communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you, or other Zuluhood Users. Please note that all communications sent or received through Zuluhood Platform during the alarm or Service Request will be stored by Zuluhood, in accordance with this Privacy Policy. However, Service Providers may choose to communicate with you directly via mobile phone or other channels that Zuluhood does not control.
What security and retention procedures and terms have we put in place to safeguard your personal data?
We observe reasonable procedures to prevent unauthorized access to, and the misuse of, personal data. We use appropriate business systems and procedures to protect and safeguard the personal data you give us. We also use security procedures and technical and physical restrictions for accessing and using the personal data on the servers we use. Only authorized personnel are permitted to access personal data during their work. Your password, however, will always be encrypted and is never shared with us. For that reason, we advise you to add a valid e-mail address to your Zuluhood profile, as we won’t be able to help you recover your Zuluhood account without it.
If we use automated means to process personal data which produces legal effects or significantly affects you, we will implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention, as previously described for conduction of the KYC verification method.
We will use the implemented safety mechanisms for the entire duration of the retention period as well. When determining the retention period of personal data, we will consider applicable laws and regulations, your interests, recommendations of supervisory authorities and other circumstances relevant to determine appropriate retention time for individual categories of personal data. In each new processing, we will consider whether the proposed retention period is necessary to achieve a particular processing purpose. When storing personal data, we take care that each processing is fair, proportionate and in accordance with the purposes for which personal data is collected.
We retain your personal data for as long as we deem it necessary to enable you to use our services, to provide our services to you (including maintaining your Zuluhood Account (if created)), to comply with applicable laws, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities. All personal data we retain will be subject to this Privacy Policy.
In certain circumstances, it may be necessary to keep personal data for a longer period of time in order to comply with legal and other regulations, for the purpose of proving in court or other proceedings, or for the operational needs of Zuluhood. Premature deletion or destruction of personal data could sometimes result in non-compliance with applicable regulations, inability to defend oneself in court or other proceedings, operational difficulties, or damages.
Personal data that are no longer needed are deleted or destroyed in a timely manner (if permitted by applicable law).
How do we treat the personal data of children?
To create a Zuluhood Account, to become a Watcher or a User who founds his/her Tribe, you must be at least 18 years old. A child (a person under the age of 18) may become a Zuluhood User only by being selected as a Tribe Member from the contact list of an adult registered Zuluhood User. After such a User selects the child as a Tribe Member, Zuluhood will send an invitation to the child’s phone number to download Zuluhood Mobile App and register as a Tribe Member. Children can only use our Zuluhood Mobile App in the role of Tribe Member.
For children (persons younger than 18 years) the use of any of our Zuluhood Services is only allowed with the consent of a parent or a legal guardian. Therefore, when you are inviting a child to your Zuluhood Account in the role of Tribe Member, make sure that you can prove that you are the child’s parent or a legal guardian or have a valid consent of the child’s parent or a legal guardian. We invite you to control and approve the child’s public profile in Zuluhood Mobile App, as you will be able to check it in your Home Tribe details since the child’s public profile could be shared with your other Tribe Members and your Watchers.
If we become aware that we process information of a child under 18 years old without the valid consent of a 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 but, as explained below, you may be able to make such changes yourself);
- 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 the 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 interest or the 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 the exercise of your rights, please contact us by contacting our Data Protection Officer at privacy@zuluhood.com. You may also contact your local data protection authority.
How to contact us?
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 Croatia and has its offices at Rudeška cesta 246, 10000 Zagreb, Croatia. If you have any questions about this Privacy Policy or about our processing of your personal data, please contact our data protection officer via privacy@zuluhood.com and we will get right back to you.