Last updated: 09.05.2024.
This privacy policy (“Privacy Policy”) governs and explains how Zihulo, a subsidiary of Opinodo ApS, (hereinafter referred to as “Zihulo”, “we”, “us”, “our”), collects, stores, shares, and protects Personal Information (defined below) about each participant, individual, user or visitor (collectively “you” or “your”) when you visit and use our website located at https://zihulo.com/ (“Website”); and/or Services (as defined under Section 2.1 of Zihulo’s Terms of Service).
In accordance with Zihulo’s Terms of Service, you acknowledge and understand that your use of our Website, Services and participation in any Survey (as defined under Section 2.2 of Zihulo’s Terms of Service) administered by our Third Party Providers (as defined under Section 2.1 of Zihulo’s Terms of Service) and hosted on our Website is completely voluntary. As such, the Personal Information you provide to Zihulo when accessing our Website will be collected, stored, processed, used and disclosed with your consent and in accordance with the terms of this Privacy Policy. If there are any terms in this Privacy Policy which you do not agree with, please discontinue using our Website and Services immediately.
You acknowledge that any Personal Information which is collected by our Third Party Providers from your participation in any Survey, will not be subject to the terms of this Privacy Policy.
Zihulo may update and modify this Privacy Policy from time to time to keep abreast of current privacy and data protection laws. We, therefore, strongly recommend that you visit this page regularly in order to keep yourself up to date on the manner in which we collect, store, share, and protect your Personal Information.
PLEASE NOTE: In an effort to make Zihulo’s Privacy Policy easier to understand, Zihulo has translated this Privacy Policy from English to various other languages using machine translation. As a result, you acknowledge and understand that any translated version of our Privacy Policy may contain errors and inaccurate terminology. As such, Zihulo shall not be liable or responsible for any errors or inaccurate terminology contained in the translated Privacy Policy.
The following capitalized words are defined as follows under this Privacy Policy:
“Device” means any computer, mobile phone or other device that you use to access Zihulo’s Website and Services.
“Personal Information” means any information about an individual from which can be used to identify that person, such as your name, email address, home address, phone number, device information, geolocation, profile activities, etc. Personal Information does not include data where the identity of the individual has been removed (i.e., anonymous data).
Zihulo may collect, use, and store Personal Information as follows:
● Identity data includes Personal Information that could identify you, such as your full name, date of birth, gender, occupation, pets, income, and email address when you sign up for a User Account (as defined under Section 4.1 of Zihulo’s Terms of Service) on the Website;
● Contact data which includes data such as zip/postal code and email address, and any other data you provide us when registered for a User Account on the Website;
● Financial data includes your PayPal or Paysera account details, and the amount of Compensation (as defined under Section 8.1 of Zihulo’s Terms of Service) you have earned completing Surveys;
● Profile data includes your username and password, your interests, preferences, and feedback;
● Marketing data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
There are certain types of information that is collected automatically by technology, and which does not reveal identifiable information that may identify you, but may include the following information:
● Device data (includes device type, device identifiers, device characteristics, etc.)
● Usage data (includes your interactions, activities, and choices you make when accessing and using the Website and Services); and
● Technical data (includes your Internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, Survey start and completion dates, and other technology on the Devices you use to access the Website and Services.
The information that Zihulo collects using technological means is solely for the purposes of improving our Website, internal analytics, and for reporting purposes.
Zihulo uses various methods to collect Personal Information from and about you including through:
● Direct interactions. You may provide us with your identity and contact data by completing our registration process and by corresponding with us via email. This includes Personal Information you provide when you:
● create a User Account on our Website;
● use the Services;
● request marketing to be sent to you;
● participate in a Survey; or
● provide us with feedback or contact us.
● Automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies. This information is collected automatically and is used only to identify potential cases of abuse, resolve technical issues, optimizing the performance of the Website for a better user experience, and establish statistical information regarding your use of the Website. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
● Metadata. When you use our Website age we may collect metadata that results from such usage including: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), date and time of accessing our Website, and internet protocol address and location. The metadata will be primarily used to improve the quality of the Website Zihulo provides to you by analysing your usage behaviour in anonymised form and to prevent fraud, misuse of our information technology (IT) systems, as well as to ensure physical and network security. We may also use metadata for other purposes, including online advertising.
● Third parties or publicly available sources. We may receive both non-personal and Personal Information about you from various third parties and public sources as set out below:
● analytics providers include but is not limited to Google Analytics;
● contact and transaction data from providers of technical, platform and payment services such as Cint AB; and
● our Third Party Providers will provide us with information on your Survey results, dates you participated in Surveys and the Compensation you earned from completing the Surveys.
In general, the Personal Information you provide to Zihulo is used to help us communicate with you. For example, Zihulo uses your Personal Information to (i) make contact with you, and/or (iii) provide you with technical support.
Sensitive information is a subcategory of Personal Information that includes (without limitation) information about your racial or ethnic origin, political views, religious beliefs, sexual orientation, and biometric data. Zihulo does not engage in the processing of your genetic data or biometric data for the purposes of uniquely identifying you as a natural person, or process data concerning your health or sex life or sexual orientation.
Zihulo does not knowingly collect Personal Information from children under the age of eighteen (18) years. We therefore encourage you to obtain the assistance and consent of a parent/legal guardian when accessing our Website. A parent/legal guardian who becomes aware that his or her child has provided us with Personal Information without their consent, should contact us at support@zihulo.com.
Zihulo may collect, use, store, and disclose your Personal Information for various purposes, such as:
● customizing, personalizing, and improving your experience on the Website;
● marketing and advertising purposes;
● sending promotional information about other services that might be of interest to you;
● analytics and market research purposes that help us to improve the Website;
● complying with legal requirements and regulations;
● resolving any disputes which may arise;
● enabling participation in online Surveys;
● to better target specific Surveys and other market research programs to you;
● contacting you to invite you to participate in Surveys or other market research programs;
● contacting you to update your Personal Information;
● managing incentive programs and fulfilling your requests for such incentives;
● allowing you to participate in sweepstakes (if legally permitted in your jurisdiction);
● responding to any messages or requests you may send;
● validating your Personal Information or your answers to a Survey or other market research program;
● monitoring abuse, fix bugs and troubleshoot any technical issues you may experience;
● detecting and preventing any violations to Zihulo’s Terms of Service;
● investigating suspected fraudulent activity ((including, for example, performing identify checks or verifying malicious IPs) or violation of a third party’s rights;
● responding to duly authorized information requests by governmental authorities or where required by law; and
● any other purposes for which you have authorized.
Zihulo will always ensure that we have obtained your consent to process your Personal Information. However, in limited cases, Zihulo may use a statutory condition to process your Personal Information. If a statutory condition applies and allows Zihulo to process your Personal Information and you subsequently withdraw your consent for processing your Personal Information, you acknowledge that this will not necessarily mean that Zihulo will cease to process your Personal Information as it may be under a statutory duty to continue to process your Personal Information for a specific purpose.
PLEASE NOTE: You may receive email communications from Zihulo and/or our Third Party Providers when you participate in the Surveys or other market research programs, available on our Website. However, you can opt-out from receiving these email communications, at any time, by deleting your User Account from your User Account’s settings dashboard or contacting us at support@zihulo.com.
Personal Information may be shared, from time to time, with our authorized third party service providers, such as Zihulo’s Third Party Providers, vendors, consultants, agents, affiliates, business partners, and other third parties.
We may share Personal Information with these third parties if (i) such disclosure is necessary to achieve our legitimate business interests, (ii) you have given us your express consent to share your Personal Information for a specific purpose, (iii) we are legally required to do so in order to comply with any law, court order, or other legal process, or (iv) necessary for preventing fraudulent activities and violations of Our Terms of Service, Privacy Policy and Cookie Policy.
Personal Information may be shared with our authorized third party service providers who are providing us with certain services, including without limitation: data analysis, hosting services, promotional purposes, customer services, and email campaigns. We also engage with third party service providers to:
● send Surveys via email to you, we use Active Campaign, Sendgird and SES;
● facilitate payment via Paypal and Paysera;
● detect fraud (including, for example, performing identify checks or verifying malicious IPs) we use Cloudflare; and
● help us track website conversion success metrics we use Active Campaign.
Zihulo will take reasonable precautions and safeguards to ensure that your Personal Information is kept secure (in accordance with this Privacy Policy) when sharing Personal Information with our authorized third party service providers.
For the purposes of complying with the General Data Protection Regulation 2016/679 (“GDPR”), you have certain rights as provided under GDPR and applicable data protection laws in relation to your Personal Information. You have the right to:
● Request access to your Personal Information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
● Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
● Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel the processing of your Personal Information will impact on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful, but you do not want us to erase the data; where you need us to hold the data even if we no longer require the data as you need the data to establish, exercise or defend legal claims; or you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use your Personal Information.
● Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you are a resident in the European Economic Area (EEA) or UK and you believe
your Personal Information is being unlawfully processed, you have the right to
complain to your local data protection supervisory authority. You can find
their contact details here.
If you are a resident in Switzerland, the contact details of the data protection authorities are available here.
You may exercise any of your rights in relation to your Personal Information by written notice to Zihulo, using the contact details set out below. Should you have any cause for complaint about our use of your Personal Information, please contact Zihulo using the details provided below and we will endeavor to solve the problem for you.
To the extent that the California Consumer Privacy Act (“CCPA”) is applicable to either Zihulo or you: both parties agree to comply with all of its obligations under the CCPA; and in relation to any communication of ‘Personal Information’ as defined by the CCPA, the parties agree that no monetary or other valuable consideration is being provided for such Personal Information and therefore neither party is ‘selling’ (as defined by the CCPA) Personal Information to the other party.
The principal rights you have under the CCPA include but are not limited to:
● Right to know. You have the right to request that we provide you with details of the Personal Information (pertaining to you specifically) that we collect, use, disclose and sell. To submit a request, please submit an email request to support@zihulo.com and include ‘CCPA Right to Know’ in the subject line. In your email, please specify the details you would like to know, and specify the Personal Information you would like to access. You will be asked to provide sufficient information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the Personal Information at issue. We will respond to your request in accordance with the CCPA. In the event we deny your request, we will provide you with an explanation.
● Right to delete. You may request the deletion of Personal Information that we collect or hold about you. To submit a request to delete Personal Information, email your request to support@zihulo.com and include ‘CCPA Request to Delete’ in the subject line. Please make sure you specify in your request what Personal Information you would like us to have deleted.
● Right to non-discrimination. You have the right not to be denied access to the Landing Page just because you exercised your rights under the CCPA. However, should such Personal Information be necessary for us to provide you with access to the Landing Page or other services, we may not be able to complete the provision of the services/transaction.
● Right to opt out. You may request us to stop collecting your Personal Information (‘opt-out’ by sending us an email to support@zihulo.com. However, please note that we must wait at least twelve (12) months before asking you to opt back into the collection of your Personal Information, unless you provide us with prior authorization.
Both parties agree to notify the other immediately if it receives any complaint, notice, or communication that directly or indirectly relates to either party’s compliance with the CCPA. Specifically, Zihulo shall notify you within ten (10) business days if we receive a verifiable consumer request under the CCPA.
Do-Not-Track (DNT) is a web browser setting that, when turned on, allows you to not have your actions monitored online and stops all tracking activities. The DNT feature was first introduced in 2010 by the US Federal Trade Commission. By the end of 2011, it was adopted by most web browsers.
Zihulo does not track its users over time and access third party websites to provide targeted advertising, and therefore Zihulo does not respond to DNT signals. Third parties cannot collect any other personally identifiable information from Zihulo’s Website unless you provide it to them directly.
The Connecticut Data Privacy Act (“CTDPA”) will affect persons that do business in Connecticut or persons who provide products and/or services to residents of Connecticut. Under the CTDPA you have the following rights in respect of your Personal Information:
● Right to confirmation and access: You have the right to confirm whether your Personal Information is being processed and to access such Personal Information, with some limited exceptions such as when such disclosure would reveal a trade secret.
● Right to correct inaccurate data: You have the right to request the correction of any inaccurate Personal Information we have about you.
● Right to delete Personal Information: You have the right to request that your Personal Information be deleted.
● Right to data portability: You have the right to request that your Personal Information be provided to you in a portable and easily accessible format, subject to technical feasibility and trade secret limitations.
● Right to opt out: You have the right to opt out of the processing of your Personal Information for certain purposes, including targeted advertising, sale of Personal Information (with some limited exceptions), or profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning you.
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this Privacy Policy.
For us to respond to your request, we need to know who you are and which right you wish to exercise. We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the Personal Information in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfil your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this Privacy Policy. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
The Virginia Consumer Data Protection Act (“VCDPA”) will affect persons that do business in Virginia or persons who provide products and/or services to residents of the Commonwealth of Virginia. The VCDPA grants users the right to access their data and requests that organizations remove their Personal Information. It also compels businesses to complete data security assessments when processing Personal Information for, among other reasons, targeted advertising and sales.
Residents of Virginia have the following rights under the VCDPA:
● the right to know if your Personal Information is being collected or processed;
● to gain access to your Personal Information collected or processed by the controller;
● to obtain a portable and usable copy of your Personal Information kept by a controller;
● to not face discrimination because you exercised their rights;
● to have inaccurate Personal Information corrected;
● to have Personal Information deleted; and
● to opt out of having your Personal Information collected or processed for the purposes of targeted advertising, sale, and profiling.
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this Privacy Policy.
For us to respond to your request, we need to know who you are and which right you wish to exercise. We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the Personal Information in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this Privacy Policy. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
This section applies to all Users who are consumers residing in the State of Colorado, according to the Colorado Privacy Act (the “CPA“). You may exercise certain rights regarding your data processed by Zihulo. In particular, you have the right to do the following:
● Opt out of the processing of your Personal Information for the purposes of targeted advertising, the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
● Access Personal Information. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information.
● Correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.
● Request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information.
● Obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this Privacy Policy.
For us to respond to your request, we need to know who you are and which right you wish to exercise. We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the Personal Information in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this Privacy Policy. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
This section applies to all users who are consumers residing in the State of Utah, according to the Consumer Privacy Act (the “UCPA“) of Utah. You may exercise certain rights regarding your data processed by Zihulo. In particular, you have the right to do the following:
● Access Personal Information. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information.
● Request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information.
● Obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
● Opt out of the processing of your Personal Information for the purposes of targeted advertising or the sale of Personal Information.
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this Privacy Policy.
For us to respond to your request, we need to know who you are and which right you wish to exercise. We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the Personal Information in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.
We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this Privacy Policy. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.
We do not charge a fee to respond to your request, for up to two requests per year.
Zihulo has adopted the Australian Privacy Principles as incorporated in the Privacy Act 1988 (“Australian Privacy Act”). As such, the Australian Privacy Act will govern the manner in which we collect, use, disclose, store, secure and dispose of your Personal Information.
If you believe that your privacy rights have been breached under the Australian Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”). The OAIC can be contacted at either www.oaic.gov.au or by calling 1300 363 992.
You expressly agree to Zihulo disclosing Personal Information to recipients/third parties located outside of Australia for the following purposes:
● to Zihulo’s related body corporates, partnerships and joint venture entities; and
● to our data hosting and Cloud-based information technology (IT) service providers.
Zihulo shall endeavour to take reasonable steps to ensure that the third party service providers/entities based outside of Australia, do not breach the privacy obligations relating to your Personal Information. As such, Zihulo will take appropriate steps to ensure that: (i) Zihulo will comply with our obligations as provided under the Australian Privacy Act or any other applicable data protection legislation, in respect of the transfer of your Personal Information while such Personal Information remains in Zihulo’s possession or under our control; and (ii) the recipient/third party of the Personal Information outside of Australia is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the Australian Privacy Act or any other applicable data protection legislation.
The General Data Protection Law (“LGPD” – in Portuguese) in Brazil regulates the use and processing of all Personal Information belonging to Brazilian residents. Under Article 18 of the LGPD you have the right to:
● confirm about the processing of your Personal Information;
● access to your Personal Information on request;
● request the correction of you Personal Information that is inaccurate, incomplete, or out-of-date;
● request the anonymization, erasure, or blocking or your Personal Information if it is unnecessary, excessive, or has been processed in violation of the law;
● request the deletion of your Personal Information;
● request the transfer of your Personal Information to another organization;
●
be kept informed about the
third parties your Personal Information is shared with;
refuse consent and be informed of the consequences; and
● revoke or withdraw consent to the processing of your Personal Information.
As such, Zihulo:
● Zihulo will not collect, use or store any information or data about you without first obtaining your express authorization in accordance with the LGPD.
● Any use by Zihulo of your Personal Information will comply with the LGPD.
● Zihulo will obtain your express authorization to collect, use or share your Personal Information with third parties on your behalf.
● Zihulo will obtain your consent when using cookies, so as to avail you of the option to opt-out or remove the cookies to the extent required by the LGPD.
● Zihulo will take additional measures, where necessary, to comply with any provisions of the LGPD, which limits the transmission of unsolicited commercial emails.
You expressly agree that Zihulo may transfer your Personal Information to servers located outside your country. As such, Zihulo will take appropriate steps to ensure that: (i) we will comply with our obligations as provided under the GDPR, CCPA or any other applicable data protection legislation, in respect of the transfer of your Personal Information while such Personal Information remains in Zihulo’s possession or under our control; and (ii) the recipient/third party of the Personal Information is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the GDPR, CCPA or any other applicable data protection legislation.
Zihulo will take all reasonable steps to keep your Personal Information protected. We have put in place appropriate administrative, technical and physical security measures that include:
● Physical security – Zihulo’s information systems and technical infrastructure are hosted within world-class, SOC 2 accredited data centers. Physical security controls at these data centers include 24×7 monitoring, cameras, visitor logs, entry limitations, and all that you would expect at a high-security data processing facility.
● Access control – Access to Zihulo’s technology resources is only permitted through secure connectivity (e.g., VPN, SSH, HTTPS). Our production password policy requires complexity, expiration, and lockout and disallows reuse. Zihulo grants access on a need to know on the basis of least privilege rules, reviews permissions quarterly, and revokes access immediately after employee termination.
● Development – Our development team employs secure coding techniques and best practices, focused around the OWASP Top Ten. Developers are formally trained in secure web application development practices upon hire and annually. Development, testing, and production environments are separated. All changes are peer reviewed and logged for performance, audit, and forensic purposes prior to deployment into the production environment.
● Encryption – Zihulo encrypts all data at rest in our data centers using AES 256-based encryption.
● Logging and monitoring – Application and infrastructure systems log information to a centrally managed log repository for troubleshooting, security reviews, and analysis by authorized Zihulo personnel. Logs are preserved in accordance with regulatory requirements. We will provide customers with reasonable assistance and access to logs in the event of a security incident impacting their account.
You acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while Zihulo strives to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another registered user on the Website and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite Zihulo’s best efforts.
Zihulo will only store/retain your Personal Information no longer than it is necessary to fulfil the purposes for which we collected your Personal Information, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements; and providing that your User account remains active (i.e. in the event of inactivity your User Account will be deleted in accordance with Section 4.7 of Zihulo’s Terms of Service).
We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When your Personal Information is no longer needed for the purpose for which such Personal Information was collected, we will take reasonable steps to destroy, delete or permanently de-identify your Personal Information.
Zihulo may collect or receive information that third party service providers may provide about you when using the Website. Zihulo may also obtain information from such third-party service providers and combine that with information Zihulo collects through your use of the Website. The following information is collected and/or obtained from third parties:
● Google Analytics – We use this analytical tool to help us analyze (a) how users use the Website, by noting when you use the Website, and (b) usage data. The information collected will be disclosed to or collected directly by the applicable analytical tool Zihulo is using. Such information is collected as a means to provide, improve, and develop the Website, so as to create a safer and trusted environment when you use the Website. The data collected from Google Analytics is aggregated and anonymous, and does not therefore include identifiable information
Zihulo’s Website runs ads from Google Adsense. In order to ensure that users are seeing ads that are relevant to their search intent and activity on the Internet, Google places cookies owned by Doubleclick. This way, Google can identify users, and run ads that are user-specific to improve digital advertising. Users may remove Doubleclick cookies by changing the settings of their browser. If you want to learn more about digital advertising and how you can keep your Personal Information from being processed this way, please visit www.aboutads.info/choices.
You can stop all collection of Personal Information by Zihulo by not accessing the Website, or by requesting to opt-out via email at support@zihulo.com.
Zihulo reserves the right to update and change this Privacy Policy from time to time in Zihulo’s sole discretion. The changed Privacy Policy will have an updated ‘revised’ date that will be visible on top of this page. The updated version will be effective as soon as it is published on Zihulo’s Website.
You shall be solely responsible for checking this Privacy Policy periodically, to stay abreast of any changes to the Privacy Policy. If there are any terms and conditions you do not agree with, please discontinue using the Website and Services immediately.
By continuing to use the Website and Services, following the posting of any changes to this Privacy Policy, you agree that you will be subject to the newly modified terms and conditions provided in Zihulo’s Privacy Policy.
If you have any questions about this Privacy Policy or about the use and collection of Personal Information, contact us via email at support@zihulo.com. We will get back to you as quickly as possible!