EFFECTIVE DATE: 1 June 2018
This website, www.zukul.com (hereinafter referred to as the “Website”) is owned and operated by MSL Systems Ltd (hereinafter referred to as “MSL”).
This policy sets out:
We have tried to keep it as simple as possible, but if you're not familiar with terms like cookies, IP addresses, and browsers, then read about these key terms first. Your privacy matters to MSL so, whether you are new to MSL or a long-time user, please do take the time to get to know our practices and, if you have any questions, please contact us at firstname.lastname@example.org.
A. WHAT WE COLLECT
1. The information we collect about you may include:
2. When you opt in for our Newsletter, or marketing materials, we collect your email address and name.
3. As is true of most websites, but subject to your browser settings, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
B. HOW WE USE YOUR PERSONAL INFORMATION
1. We need to use the personal information described in section A in order to offer the Zukul Services to you, including for the following purposes:
2. When you contact MSL, we may keep a record of your communication to assist us and you in ensuring that you get the best from our services.
3. You can contact us at any time to:
Please contact us at email@example.com with any questions relating to your information that we control.
C. HOW WE SHARE YOUR PERSONAL INFORMATION
1. From time to time, we engage unaffiliated third parties and their affiliates, agents, and subcontractors ("Service Providers") to perform certain technological or administrative services in connection with the Zukul Services. For example, a Service Provider may be asked to operate a Verification Network, process transactions, provide credit reports or assessments, verify customer identities, detect suspicious transactions, perform security services, and manage or audit our operations. In some cases, a Service Provider will be collecting your personal information from other sources on our behalf to fulfil the purposes set out in section B. We also may use a Service Provider to host and administer one or more of our Websites, process and store data, and fulfil similar technology-related functions on our behalf. In these circumstances, the personal information that the Service Provider receives is limited to the personal information needed to render their service to us.
2. In certain cases, we may also share some of the personal information we collect with carefully selected business partners, who are first required to sign an agreement that obligates them to keep the information confidential and secure and prohibits them from using it for unauthorized purposes.
3. We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent fraud or abuse, or to protect the rights, property or personal safety of MSL, its customers, employees, service providers, or the public.
4. For clients with a Zukul Account, the data controller is based in the United kingdom, and data is stored in the USA and other locations within the EEA. MSL reserves the right to share your personal information internally between USA and the EEA to the extent necessary for the purpose of providing Zukul Services to you. Should you not consent to such disclosures, please do not utilise Zukul Services.
6. We may provide your personal information to companies that provide services to help us with our business activities such as emailing newsletters or offering client service. These companies are authorized to use your personal information only as necessary to provide these services to us.
7. We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends or publish market research.
8. We will disclose otherwise confidential personal data and confidential information if we are compelled to do so by laws and regulations applicable to us and/or our agents.
D. HOW WE COMMUNICATE WITH YOU
1. Communications between you and MSL may be conducted by mail, online or by other electronic means. Any instructions that you give to us in any such manner will have the same legal effect as if you gave them to us in original written form. You agree that we may contact you electronically in response to a request, inquiry, or complaint, as otherwise solicited by you, or as permitted or required by law.
2. We may also communicate with you from time to time electronically about news, promotions, special offers and other information from MSL, regarding either MSL or its selected partners. If you wish to unsubscribe to marketing emails from MSL please contact firstname.lastname@example.org. We will strive to honour your request as soon as possible, and in any event within the next 10 business days. Please note, however, that this request will apply only to marketing emails and not to certain account-based information emails which will continue to be sent to account holders. We are not responsible for any additional information you provide directly to these partners, and we encourage you to become familiar with their privacy and security practices and policies before disclosing information to them.
E. INFORMATION STORAGE AND RETENTION
2. Your information may also be processed by employees or consultants who are located outside of the EEA. By submitting your personal data, you agree to this processing, storing, and transfer.
3. We will retain your information for as long as you have an open Zukul Account or as is needed to provide you Zukul Services. If you wish to terminate Zukul Services or request that we no longer use your information to provide you services, please contact us on email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
F. COOKIES AND OTHER TRACKING TECHNOLOGIES
1. You can visit our website without giving away your personal information. MSL uses Google Analytics and Cookies in order to improve our service, user experience and analyse how the website is used. As is true of most websites, but subject to your browser settings, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, languages, age, gender, interests, device information date/time stamp, and clickstream data.
2. We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users' movements around the site, and to gather demographic information about our user base as a whole.
3. We do not link this automatically collected data to personally identifiable information.
G. CHANGES TO THIS POLICY