PRIVACY POLICY
 

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”).

We always want our policies to be clear and easy to understand, so this policy offers a simple breakdown of how we handle your personal information in connection with the Website and the services. This policy is incorporated into the User Agreement and the Statement of Policies & Procedures and the Cookie Policy and the Refund Policy.

By using our Website, using or applying for a Zukul Account (“Zukul Services”), you are consenting to being bound by this Privacy Policy.

This policy sets out:

• What information we collect and why we collect it;
   
• How we use that information and how we secure it;
   
• Any third parties with access to it and use of cookies;
   
• The choices you have with regard to the use of your personal information.

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 teamzukul@gmail.com.

A. WHAT WE COLLECT

1. The information we collect about you may include:

• Contact information (such as your name, email and postal addresses, telephone number, and country of residence) that you provide by completing forms on the Website, by telephone, or through a paper application form;
• Information permitting us to offer the Zukul Services to you, including details relating to your personal bank accounts or virtual currency wallet, details allowing us to prevent and detect money laundering and terrorist financing activities, copies of your current valid government-issued photo identification, and/or such other identifying and verifying information as we require from time to time in our discretion, and credit bureau information about you for purposes of confirming your identity under applicable "know-your-client" rules;
• Details about your finances that you provide to us or permit us to collect through third party service providers;
• Your login and password details;
• Details of any transactions you make through the Zukul Services;
• Information about your activity on the Website, such as your IP address, the pages you have visited and the device or browser you use;
• Information provided via your mobile devices, such as your location, phone ID, mobile user name, password, contacts, location;
• Communications with us (for example, when you ask for support, send us requests, questions or comments, or report a problem, whether by mail, telephone, fax, online, or by any other means);
• Information that you submit through the Website, including in the form of comments, contributions to discussions, or messages to other users; and
• Demographic information;
• Geolocation information;
• Data mining and financial profiling.

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:

• Ascertaining whether to approve you for use of the Zukul Services when you apply to use the Zukul Services;
• Identifying you when you sign in to your Zukul Account;
• Processing transactions in your Zukul Services Account, helping you submit your Bitcoin transaction request for confirmation to the Verification Network, and communicating with other counterparties in respect of the Zukul Services;​
• Administering your Zukul Services Account, understanding your needs as a client, and monitoring your satisfaction with the Zukul Services;
• Contacting you about the status of the Zukul Services (for example, to inform you of changes to or the termination of particular Zukul Services, or to respond to a question, comment or complaint);
• Complying with legal requirements, including those imposed by laws, regulations, court orders, and regulatory guidelines, policies and procedures, in the countries in which we operate, including tax,  or reporting obligations;
• Detection of suspicious transactions, including transactions involving fraud, money laundering or terrorist financing activities;
• Managing invoicing, accounting and information security services related to our transactions with you;
• Protecting against harm to the rights, property or safety of MSL, its clients, employees, service providers, or the public;
• Internal management purposes, including planning, resource allocation, policy development, quality improvement, compliance, monitoring, audit, evaluation and reporting;
• Improving the Zukul Services;
• Managing your communications preferences; and​
• Maintaining ownership records.

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:

• Request information that MSL has about you;
• Correct any information MSL has about you;

Please contact us at teamzukul@gmail.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.

5. We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We will not sell, rent, loan, trade, or lease any of your personal information collected, including application forms, financial data, or email addresses. MSL may ask for your permission by email to disclose your personal data to service providers not affiliated with MSL, but you have the right to refuse.

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 teamzukul@gmail.com. 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

1. We may process your personal information on a server located outside the country where you live, and such personal information may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). Wherever we process or store your personal information we will, in addition to complying with all applicable laws and regulations in that jurisdiction, comply with this Privacy Policy.

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 teamzukul@gmail.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

LOG FILES

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.

4. We reserve the right to use a third-party tracking service, Google Analytics, which uses cookies to track aggregate non-personally identifiable information about visitors to our site such as number of visits, searched pages and browser type to improve our website and client experience.

COOKIES

5. Cookies are small pieces of information which are placed in your computer’s memory when you visit a website. MSL uses cookies to recognize you as a repeat visitor, to identify your browser type, to keep track of online patterns and preferences in order to better understand you as a customer, and to improve the quality of the Website and Zukul Services. When you enter our Website, our servers (or those of our Service Providers) will recognize your computer but not who is using it. However, by associating the identification numbers in the cookies with other customer information when, for example, you log in to the Zukul Services, we know that the cookie information relates to you.

1. It is always open to you to modify your web browser settings to prevent the placing of cookies or to notify you each time a cookie is set. The website www.allaboutcookies.org contains additional useful information on how to block or control cookies using different browsers. However, by blocking or deleting cookies used on the Zukul Services, you may not be able to take full advantage of the Zukul Services.
2. The Website and the Zukul Services may allow you to interact with various plugins from a large variety of social media sites such as Facebook, Twitter, LinkedIn or Instagram and various others. In such cases, there may be a flow of your personal information between MSL and such social media sites. Your use of these plugins will be governed by each social media site's privacy policy and not this privacy policy. We encourage you to become familiar with each social media site's privacy and security practices and policies before enabling such plugins.

G. CHANGES TO THIS POLICY

1. It may become necessary to change the terms of this Privacy Policy from time to time. We reserve the right to change this Privacy Policy as necessary to comply with law or for legitimate business purposes. By continuing to use the Zukul Services, you agree to be bound by the updates to this Privacy Policy. Please check back frequently; you will be able to see if changes have been made by looking at the top of the Privacy Policy for the date it was last updated. Last updated: 1 June 2018