We record that data collected, used and processed in the course of our operations is processed through the software known as Easypublish CMS, developed, maintained and secured by a third party, Escio AS, situated in Norway, together with certain other proprietary brand software providers and we have verified that all data collection and processing software services in use by Zulufadder are fully compliant with applicable privacy legislation.
1. INFORMATION WE COLLECT FROM SPONSORS, BENEFICIARIES AND THIRD PARTIES
There are three possible categories of information we collect.
1.1 Information You Give to Us
1.1.1 Information that is necessary for the control and recording of sponsor information, beneficiary information, donations and online purchases.
We ask for and collect the following personal information about you. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with a comprehensive service.
Regarding beneficiary information, we advise that the conditions applicable to a child’s consent in relation to information services, applicable to Zulufadder, are as set out in Art. 8 of the European General Data Protection Regulation (GDPR) conditions and modified by the terms of the South African Protection of Personal Information (POPI) Act, Part C read with Definition 1 that states that a child is a natural person, under the age of 18, who is not legally competent.
In other words, any person under the age of 18 becoming a beneficiary of Zulufadder has to have the permission of his or her legal guardian.
- Sponsor Information. When you sign up as a sponsor, we require certain information such as your first name, last name and contact details. We will require your identification details if your tax authorities request it.
- Beneficiary Information. When we register you as a beneficiary of Zulufadder, we require certain information such as your first name, last name, contact details, identity number, family details, health status, education details, agreement to share information with others, use of information for promotional purposes and, where applicable, legal guardian’s details and approval.
- Payment Information. To use certain features of the Zulufadder Services (such as making a donation, agreeing to pay a regular amount and purchasing goods from our online shop) we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via third-party service providers).
1.1.2 Information you choose to give us.
You may choose to provide us with additional personal information. This additional information will be processed based on your consent.
- Additional Sponsor Information. You may choose to provide additional information as part of your Zulufadder profile (such as gender, preferred language(s), city, and a personal description). This information, as selected in your profile, is only visible to you and us.
- Other Sponsor Information. You may otherwise choose to provide us with information when you complete a form, conduct a search, update or add information to your profile, respond to surveys or use other features of our services.
1.1.3 Information that is necessary for the use of the Payment Services.
The Data Controller needs to collect the following information, as it is necessary for the adequate performance of our contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:
- Payment Information. When you use the Payment Services, the Data Controller requires certain financial information (like your bank account or credit card information) to process payments and comply with applicable law.
- Identity Verification and Other Information. If you are a sponsor, the Data Controller may require identity verification information (such as images or details of your government issued ID, passport, national ID card, or driver’s license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.
1.2 Information We Automatically Collect from Your Use of the Zulufadder Services and Payment Services
When you use the Zulufadder Services and the Payment Services, we and/or our third-party service providers automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Zulufadder Services and Payment Services.
- Payment Transaction Information. Zulufadder, through its third-party service providers, collects information related to your payment transactions including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN or SWIFT information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Zulufadder and to comply with the provisions of the Payment Services.
1.3 Information We Collect from Third Parties
We do not require or request information about you from third parties. However, we are provided with details of your financial transactions with us, by our third-party service providers.
2. HOW WE USE INFORMATION WE COLLECT
We use, save, and process information, including personal information, about you to provide, understand, improve, and develop the Zulufadder Services, create and maintain a trusted and safer environment and comply with our legal obligations to both sponsors and beneficiaries.
2.1 Provide, Improve and Develop the Zulufadder Services
- Enable you to access and use the Zulufadder Services to obtain general information as well as specific information about your sponsor child/children and to make payments.
- Provide customer service.
- Send you newsletters or support messages, updates and account notifications.
We process this information given our legitimate interest in providing you with all relevant information about your sponsor child/children, information about Zulufadder activities and the current state of your account.
2.2 Create and Maintain a Trusted and Safer Environment
- Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Verify or authenticate information or identifications provided by you.
- Comply with our legal obligations.
- Resolve any disputes with sponsors and beneficiaries and enforce our agreements with third parties.
- Enforce our policies.
- In connection with the activities above, we may find it necessary to suspend the account of a sponsor or terminate the service to a beneficiary based on information and/or actions identified by Zulufadder.
We process this information given our legitimate interest in protecting Zulufadder sponsors and beneficiaries and to comply with applicable laws.
2.3 Provide, Personalise, Measure, and Improve our Services
- Send you promotional messages, newsletters and other information that may be of interest to you.
- Personalise, measure and improve the Zulufadder Services.
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking promotional activities to provide information that may be of interest to you. You can opt-out of receiving communications from us by following the unsubscribe instructions included in our communications or changing your notification settings within your Zulufadder profile.
2.4 How the Data Controller uses the Payments Information Collected
- Enable you to access and use the Payment Services.
- Detect and prevent fraud, abuse, security incidents, and other harmful activity.
- Conduct security investigations and risk assessments.
- Conduct checks against databases and other information sources.
- Comply with legal obligations (such as anti-money laundering regulations).
- Enforce the Payment Terms and other payment policies.
- With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.
The Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.
3. SHARING & DISCLOSURE
3.1 Access to Beneficiary Profiles
Zulufadder allows Sponsors to have access to the profiles of their sponsor child/children.
3.2 Disclosure to Third Parties
Zulufadder shares information with third-party service providers in order to accurately record financial transactions and to facilitate email communications that can include newsletters, promotional material, account updates and personal communication.
Based on our legitimate interest to promote communication with and provide information about Beneficiaries to Sponsors, Sponsors are provided with specific and limited on-line access to their sponsor child/children.
3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights
Zulufadder may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Zulufadder, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our policies or other agreements, or (v) to protect the rights, property or personal safety of Zulufadder, its employees, its sponsors, its beneficiaries or members of the public.
Where appropriate, we may notify sponsors or beneficiaries about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Zulufadder’s property, its sponsors or beneficiaries. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that sponsor or beneficiary about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.
3.4 Service Providers
Zulufadder uses certain third-party service providers to help us provide services related to the Zulufadder Services and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”).
All our third-party service providers are compliant with applicable privacy legislation.
In these cases, Zulufadder will need to share your information, including personal information, to these service providers to ensure the adequate performance of our contract with you.
3.5 Social Media Services
Zulufadder uses Social Media Services such as Facebook, Google, Twitter, YouTube, LinkedIn, and Instagram to promote traffic to our website.
These processing activities are based on our legitimate interest in attracting new sponsors to Zulufadder and to inform any person who may enquire about our activities.
We do not share your personal data with these social media services.
Should you decide to follow us on any of these services you should be aware that any personal data shared with them is not controlled or supervised by Zulufadder, therefore, any questions regarding how your social media service provider processes your personal data should be directed to such provider.
Please note that you may, at any time ask a social media services provider to cease processing your data.
4. YOUR RIGHTS
You may exercise any of the rights described in this section by sending an email to Zulufadder at email@example.com.
4.1 Managing Your Information
You may access and update some of your information through your Profile settings. You are responsible for keeping your personal information up-to-date.
4.2 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself in your Zulufadder profile).
4.3 Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
4.4 Data Retention and Erasure
We retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information or participate in the Zulufadder service, you can request that we erase your personal information and close your Zulufadder profile. Please note that if you request the erasure of your personal information we may be required by law to retain it for a certain time in part or in full.
4.5 Withdrawing Consent and Restriction of Processing
Where you have provided your consent to the processing of your personal information by Zulufadder you may withdraw your consent at any time by changing your profile settings or by sending a communication to Zulufadder specifying which consent you are withdrawing.
4.6 Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Zulufadder with the competent data protection authorities.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. If you know or have reason to believe that your Zulufadder profile information has been lost, stolen, misappropriated or otherwise compromised, or in case of any actual or suspected unauthorized use of your Zulufadder profile, please contact us following the instructions in the Contact Us section below.
7. CONTACT US
Created: April 26, 2018