Last updated: April 7, 2021
ZuluTails LLC (“we”, “our”, “us,” “ZuluTails”) are committed to protecting and respecting your privacy. We are a corporation incorporated in Delaware, United States with an office at 4230 N. Buffalo Rd. STE 7, Orchard Park, NY 14127, and for the purpose of the General Data Protection Regulation (the “GDPR”), we are the data controller.
Information We Collect and Use
Information You Provide to Us
When using the Services or registering as a user, we receive and store information you enter or provide to us, which may include, but is not limited to, your name, billing address, shipping address, email address, phone number, and for potential ZuluTails members any other information you provide. When you submit or post information to the Services for public display, including personal data such as your name, photos, comments, reviews, and any other information you choose to post, we receive and store that public information.
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our Services, we may use your information to:
- Communicate with you
- Contact you via telephone, SMS, or email
- Identify our users
- Administer and provide our Services and customer support per your request
- Personalize our Services for you
- Improve and develop our Services
- Analyze your eligibility for ZuluTails Services per your request
- Enforce the terms and conditions of our Services
- If you have not opted out of marketing, communicate with you about products, services, promotions, events, and other news and information we think will be of interest to you; or
- Provide third parties with statistical and transactional information about our users (but those third parties will not be able to identify any individual user from that information).
Information Collected Automatically
When you use the Services, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, URL, IP address, cookie information (described in more detail below), the page you requested, use information regarding your use of the Services, browser information, and any other data that is tied to such information.
As it is in our legitimate interests to process your data to provide effective services and useful content to you, we collect this data to:
- Personalize our Services to ensure content from our Services is presented in the most effective manner for you and your device
- Monitor and analyze trends, usage, and activity in connection with our Services to improve our Services
- Monitor customer transaction frequency, products bought, viewed, and favorited to personalize and improve content for our customers
- Administer our Services, including the website, and for internal operations, to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis
- Keep our Services safe and secure; and
- Measure and understand the effectiveness of the content we serve to you and others.
Payment and shipping information
When you purchase a product from our Services, we collect your name, billing address, email address, and payment card information to process your payment. We also collect your shipping address and contact details to ship the product to you. We process this data to perform our contract with you.
Friends and Contacts Information
You may choose to provide us with another person’s e-mail address or social network profile information so we can invite that person to create an account on the Service and become your friend. We use this information to contact and, if necessary, remind that person about the invitation. By providing us with another person’s e-mail address, you represent to us that you have obtained the consent of the person concerned with respect to such disclosure to us of their personal information. We may disclose such information if required to do so to comply with legal process, as described below.
How We Share Information About You
To compliment, improve, and extend the services we offer, we may share the following categories of information for a business purpose:
- Commercial information
- Internet or other electronic network activity information; and
- Geolocation information.
We share those categories of information with the following types of service providers for business purposes:
- IT service providers, who we use to provision, maintain, and improve our Services, including, providing customer service, our email services, to process our customer relationship management information and to conduct software development works in building the components of our Services
- Payment services providers, who we use to process your payments when you order products from our Services
- Software development partners, who we use to build, maintain, manage, and improve the systems that support our Services
- Web Analytics service providers, who we use to collect and process certain analytical data which helps us understand how you engage with our Services
- Customer segmentation and personalization services providers, who we use to process and receive transactional and behavioral data about users of our Services in order to provide more personalized experiences for you while using our Services
- Delivery services providers for our domestic and international customers, who we use to deliver our products to you; and
- Third-party advertisers, who we use to process about you and other users of our Services to serve advertisements about goods and services of interest to you when you visit our Services.
We do not provide your personal information to other companies in exchange for monetary payment.
Most of our third-party vendors are located in the United States but we may process your personal data globally. Please see “Where do we store your information” for more information.
We will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- Comply with a legal obligation, process, or request
- Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof
- Detect, prevent, or otherwise address security, fraud, or technical issues; or
- Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
We will also disclose your information to third parties:
- In the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
- If we or substantially all our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
Cookies and Similar Technologies
The types of cookies we use can be broken down as follows:
- Strictly necessary cookies. These are cookies that are required for the operation of our Services, including our website. They include, for example, cookies that enable you to use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. These types of cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using our Services. This assists us in improving the way our Services work, for example, by ensuring that you are finding what you are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our website. They allow us to personalize content, recognize users and remember user preferences.
- Targeting cookies. These cookies record a user's visit to a website, the individual pages visited, and the links followed. This type of cookies also tracks your movements across different websites and creates profiles of your general online behavior. Information collected by tracking cookies is used to serve you with targeted online advertising.
Certain cookies we use are ‘session’ cookies, while others are ‘persistent’, as described below:
- Session cookies. These are cookies that expire at the end of a browser session, which is when you exit the browser. They allow us to link your actions during a single browser session to allow you to use the website most efficiently.
- Persistent Cookies. In contrast to session cookies, persistent cookies are stored on your equipment between browsing sessions. They therefore enable us to “recognize” you when you return to use our Services, including our website.
Most browsers have an option for disabling the cookie feature, which will prevent your browser from accepting cookies, as well as (depending on your browser software) allow you to decide on acceptance of cookies in a variety of ways. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.
Where do we store your information?
The information that we collect from you will be transferred to and stored at/processed in the United States by us or our third-party vendors. The people processing your personal data are engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
How long do we store your information?
We retain the information we collect from and about you for as long as necessary. We may retain certain information for legitimate business purposes or as required by law.
Your access to the Services is password protected for your privacy and security. You can help prevent unauthorized access to your personal data on the Services by selecting and protecting your password, and limiting access to your computer, phone, and browser such as signing off after you have finished accessing the Services. We have security measures in place to protect your personal data. However, we cannot guarantee the security of your personal data.
Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your personal data at any time.
Privacy Practices of Third Parties and Third-Party Sites
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary to protect Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee you can exercise your rights.
- Request access to Your Personal Data. The right to access or update the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please 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 Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw your consent, we may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, we will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Your Rights under the CCPA
- The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties.
- The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
To exercise any of Your rights under the CCPA, and if you are a California resident, you can email or call us.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- From Our "Cookie Consent" notice banner
The opt out will place a cookie on Your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use to serve you ads that are targeted to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track (DNT) signals.
However, some third-party websites do keep track of Your browsing activities. If you are visiting such websites, you can set your preferences in Your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that your child has provided Us with Personal Data, please contact Us. If We become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.
Your California Privacy Rights (California’s Shine the Light Law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you would like to request more information under the California Shine the Light law, you can contact us using the contact information provided below.
California Privacy Rights for Minor Uses (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact Us using the contact information provided below and include the email address associated with Your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.