Privacy Policy

Zluri adheres to the EU-U.S. DPF Principles with regard to personal data transferred from the European Union.

Your privacy is important to us. It is Zluri Technologies Pvt. Ltd.'s together with its affiliates, namely Zluri Inc. (hereinafter referred to as the 'Company,' 'Us,' and/or 'Zluri') policy to respect your privacy regarding any information we may collect from you across our websites (http://www.zluri.com and other sites we own and operate), mobile applications (Apps), and through all other communication channels and services we offer (collectively, 'Services').

We are committed to safeguarding your privacy and ensuring the security of your personal information. We adhere to stringent information security standards and practices, including those outlined in our Information Security Management System (ISMS), to protect your data from unauthorized access, improper use, or disclosure. We continuously enhance our security procedures as new technology becomes available.

Zluri aims to provide an excellent, trusted product and service to our customers. We plan on using anonymized aggregate data to improve the product for those same customers. Moreover, we will never sell our customer's data, identity, or contact information to third parties or vendors, as that would be a violation of our promise and trust. Any feature that requires the sharing of personally identifiable information will be strictly opt-in.

1. Consent

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICES, YOU AGREE TO BE LEGALLY BOUND BY THIS POLICY AND ALL TERMS INCORPORATED BY REFERENCE. THE COMPANY RESERVES THE RIGHT TO ALTER, AMEND AND MODIFY THIS POLICY AT ITS SOLE DISCRETION. ALL SUCH AMENDMENTS AND MODIFICATIONS WILL BE DULY NOTIFIED ON THE WEBSITE. YOUR CONTINUED USE AND ACCESS OF OUR SERVICES AFTER WE PUBLISH THE CHANGES TO THIS POLICY MEANS THAT YOU HAVE CONSENTED TO THE UPDATED TERMS NOTIFIED BY US FROM TIME TO TIME. IF YOU ARE NOT AGREEABLE TO THIS POLICY, WE REQUEST YOU NOT TO ACCESS OR USE THE SERVICES. For our Terms and Conditions, please visit https://www.zluri.com/terms-and-conditions/.

2. Overview

We are committed to maintaining your privacy, and we value and appreciate your trust in us. We let you retain as much control as possible over your personal information. However, you may not visit and use our Services at any time without telling us who you are or revealing the required information about yourself. To the Company, our most important asset is our relationship with you.

We are dedicated to maintaining the confidentiality, integrity, and security of any personal information about our users. We are proud of our privacy practices and the strength of our Website and App security and want you to know how we protect your information and use it to provide you the Services.

This policy does not cover the privacy practices of third parties that we do not own or control. Zluri may provide third-party content or links to websites or applications or include features that allow you to connect with third parties, such as financial institutions or other service providers. When you interact with a third party, you should read that party's privacy policy and terms of Use to understand the practices that it follows in relation to the access, storage, processing, Use, etc. of data collected by that party.

3. Data Controller

Zluri Its Affiliates, having its registered office at Plot No 136, Sri Laxmi Nilayam, Kompally in Hyderabad, India and its principal place of business at 8, The Green STE A (Street), Dover, Kent County, Delaware in the United States of America will be the controller of your personal data and other data provided to or collected by or for, or processed in connection with our Services.

4. Data Processors

Zluri engages various third-party data processors to assist in providing our Services. These processors are contractually bound to protect your data and process it only according to our instructions. The details of the Sub-processors that the Company currently is engaged with can be found at https://www.zluri.com/subprocessors/.

5. Information We Collect

We collect various types of personal information to provide and improve our Services. The specific information we collect depends on your interaction with us.

a) Personal information you provide directly:

This includes information you actively provide when you register for an account, use our Services, communicate with us, or subscribe to updates. This may include:

Contact Information: Your name, email address, phone number, company name, and postal address.
Account Information: Credentials and other details related to your user account.
Communication Content: The content of messages or attachments you choose to send us, including those sent via SMS.

b) Information Collected Automatically:

When you visit our websites or use our Services, we may automatically collect certain information about your device and usage patterns.

Log Data: Information collected by log files, including internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of this information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.
Device Data: Data about the device you're using to access our website, which may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Business Data: Data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data, and other metrics, as well as other types of information created or generated as users interact with our services.
SMS Communications Data: When you interact with us via SMS for customer support or service-related inquiries, we collect your mobile phone number, the content of your messages (if applicable), User actions (e.g., clicking links, replies like STOP or HELP), and related metadata (such as the date and time of the message delivery).

6. How We Use Your Information (Purpose of Processing)

Data obtained via a Google API Restricted Scope is limited to the restrictions outlined in Google API Services User Data Policy. We collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

To Provide and Maintain Our Services: To operate, maintain, and provide you with our website, associated applications, and core features of our platform. This includes enabling you to access and use our Services.
For Customer Support and Communication: To contact and communicate with you, either directly or through our partners, including for customer service purposes, to provide you with updates and other information relating to the Services, and to respond to your inquiries.
For SMS Communications: Specifically, we use phone numbers and SMS message content to provide transactional alerts(e.g., login OTPs, system alerts, billing notifications), direct one-on-one customer support or issue resolution, deliver product or feature updates, respond to your inquiries via SMS, and send you service-related communications, updates relevant to your account or interactions with us. It can also be used to share promotional content (only if you have explicitly opted in). Message frequency will vary depending on your account activity and selected preferences. Standard message and data rates may apply per your mobile carrier’s plan. We are not responsible for carrier charges.
To Improve and Personalize Our Services: To understand and analyze how you use our Services, improve, personalize, and expand our website, and develop new products, services, features, and functionality. This includes analytics, market research, and business development.
For Internal Operations: For internal record keeping and administrative purposes.
For Security and Fraud Prevention: To find and prevent fraud, investigate and help prevent potentially unlawful activity or activity that threatens our network, or otherwise violates your user agreement for that service.
For Legal Compliance and Dispute Resolution: To comply with our legal obligations and resolve any disputes that we may have.

7. Legal Bases for Processing

We will only collect and process personal information where we have a lawful basis for doing so. These legal bases depend on the Services you use and how you use them, meaning we collect and use your information only where:

It's necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our Services, and to protect our legal rights and interests;
You give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. We don't keep personal information for longer than is necessary or as is legally stipulated. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, Use, or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person/entity connected either directly or indirectly to you.

8. Disclosure of Personal Information to Third Parties

We may disclose personal information to:

a)Third-Party Service Providers and/or Sub-processors: If and to the extent necessary, for the purpose of enabling them to provide their services. This includes (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, maintenance or problem-solving providers, professional advisors (for example, to resolve disputes and enforce our legal agreements and policies), and payment systems operators. This also includes SMS service providers (such as Aircall), solely for the purpose of facilitating and delivering our SMS communications to you for customer support and service-related purposes. All vendors are contractually bound to process your data only for the purpose of delivering our SMS program and in compliance with CTIA and TCPA standards. All providers are contractually obligated to protect your information and are prohibited from using your personal information for any purpose other than providing these services on our behalf.

b) Third Parties to whom you consent to disclose your personal information.

c) Our employees, contractors, and/or related entities.

d) Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights.

e) Third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you. This may include parties located outside of India.

f) An entity that buys, or to which we transfer all or substantially all of our assets and business.

Important Note on Marketing:

We do not sell, rent, or share your mobile phone number or the content of your SMS communications with third parties for their marketing or promotional purposes. Your consent to receive SMS communications is specific to our direct customer support and service-related interactions.
We will not use information about user activities on the internet together with any information that would result in the user being identified without their consent for marketing purposes.
Personal information collected through SMS communications (including your phone number and message content) will not be used for marketing purposes. Our SMS communications are strictly limited to one-on-one customer support and service-related interactions.

9. Legal Disclosures and Protection

We may need to disclose information about you when required by law or legal process or if we have a good faith belief that disclosure is reasonably necessary to:

(a) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;

(b) enforce our agreements with you,

(d) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or

(e) exercise or protect the rights and safety of Zluri,

our users, personnel, or others. In addition to the circumstances described above, we may utilize the data for some statistical or other representational purposes without any disclosure of your personal data.

We may also need to disclose this data to Telecom carriers for compliance monitoring in case of SMS.

We will attempt to notify you about legal demands for your personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

10. International Transfers of Personal Information

The personal information we collect is stored and processed in India, or where we or our partners, affiliates, and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example, by using standard data protection clauses approved by the European Commission, or by requiring the recipient to adhere to other approved transfer mechanisms.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not have data protection laws equivalent to those in the jurisdiction in which you provide the information.

Data Privacy Framework

Zluri complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Zluri has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data Privacy Framework website https://www.dataprivacyframework.gov/

Zluri remains responsible and liable under the EU-U.S. DPF Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles unless Zluri proves that it is not responsible for the event giving rise to the damage.

The Federal Trade Commission has jurisdiction over Zluri’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF).

In compliance with the EU-U.S. DPF, Zluri commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF should first contact Zluri at: dpo@zluri.com

In compliance with the EU-U.S. DPF, Zluri commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF to PrivacyTrust, an alternative dispute resolution provider based in the United Kingdom. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://privacytrust.com/services/data-privacy-framework/dispute-resolution/ for more information or to file a complaint. The services of PrivacyTrust are provided at no cost to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residuals claims not resolved by other redress mechanisms. With respect to personal data received or transferred pursuant to the Data Privacy Framework.

11. Your Rights and Controlling Your Personal Information

You have the right to request:

a) Access to your personal information: You have the right to request access to the personal information we hold about you. We will provide you with a copy of the personal information we hold about you.

b) Correction of your personal information: You have the right to request that we correct any personal information that you believe is inaccurate or incomplete.

c) Deletion of your personal information: You have the right to request the deletion of your personal information, subject to legal obligations.

d) Restriction of processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.

e) Object to processing: You have the right to object to our processing of your personal information, under certain conditions.

f) Data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

g) Withdrawal of consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

h) Lodge a complaint: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

i) Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications); please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

j) SMS Opt-Out: If you wish to stop receiving SMS messages from us for customer support or service-related communications, you can typically opt out by replying "STOP" to any message you receive. We will send a confirmation message to acknowledge your opt-out. You may still receive important notices via other channels (e.g., email) if they are not related to SMS communication.k) Choice: if Personal Information covered by this Privacy Policy is to be used for a new purpose that is materially different from that for which the Personal Information was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, Zluri will provide you with an opportunity to choose whether to have your Personal Information so used or disclosed. Requests to opt out of such uses or disclosures of Personal Information should be sent to us as specified in the “ Contact Us” section below. Certain personal information, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information.” Zluri will not use Sensitive Information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Zluri has received your affirmative and explicit consent (opt-in).

12. Aggregate Anonymised Data and Usage

We may/will monitor the Use of the Services by all of our customers and use the information gathered in an aggregate and anonymous manner. You agree that we may use and publish such information, provided that such information does not incorporate any of Your Data in a personally identifiable manner. Notwithstanding the restrictions above and elsewhere in this Privacy policy, You expressly agree that the Company retains the right to use, sell, disclose, transfer, or rent any user data as long as such user data is in an aggregated anonymized form that does not include any individually identifiable user data, and/or identify you. Further, the Company retains all rights on the Use of statistical information, as well as on data and related analysis in aggregate anonymized form, deriving from the Use of the Services by its Users. For the sake of clarity, such aggregate anonymized data does not include personal data, and the User expressly authorizes the Company to use same in order to improve the functionality of the Services or to publish the statistical information in aggregate form or for any other requirement that the Company deems fit.

13. Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. We do not associate the information collected by these software utilities with your username or email address when you visit our sites.

14. Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

15. Third-Party Privacy Policies

Zluri's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options. You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites. CCPA Privacy Rights (Do Not Sell My Personal Information).

Under the CCPA, among other rights, California consumers have the right to request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers. Request that a business deletes any personal data about the consumer that a business has collected. Request that a business that sells a consumer's personal data not sell the consumer's personal data. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

16. GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

17. Security of Information

We work to protect the security of your information during transmission of data by using Secure Sockets Layer (SSL) software, which encrypts information you input. We constantly re-evaluate our privacy and security processes and adapt them as necessary to deal with new challenges.

We make every effort to allow you to retain the anonymity of your personal identity, and you are free to choose a login ID, email address, and password that keeps your personal identity anonymous. Access to your registration information and your personal data is strictly restricted to our employees and contractors, on a need-to-know basis, in order to operate, develop or improve the Services.

You agree and understand that you are responsible for maintaining the confidentiality of all information provided to the Company while registering Yourself, which includes your login ID, email address, and the passwords for the same. You are fully responsible for all activities that occur under your email address, password, or account, and you shall ensure to exit from your account at the end of each Use. The Company will send all correspondences, notices, and any other communication to the email address furnished by you.

In the event of your becoming aware of any unauthorized access or misuse of your account/ information, you must forthwith notify the Company at dpo@zluri.com. The Company cannot and will not be liable for any loss or damage arising from your failure to comply with this provision.

For more details and specifics - https://www.zluri.com/security/

The rest of this Privacy Policy goes into more specific legal details, and if you have questions, feel free to reach out at dpo@zluri.com.

18. Changes to This Policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example, changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

19. Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

20. Governing Law and Jurisdiction

a) For users in the Asia region: If you choose to access or use our Services, your visit, Use, and any dispute over privacy are subject to this Privacy Policy. Any disputes arising out of this Privacy Policy and the Services shall be governed by the laws of India, and the courts of Hyderabad, India, shall have exclusive jurisdiction. Any dispute arising out of or in relation to the Privacy Policy shall be resolved through arbitration in Hyderabad.

b) For users in the other region: If you choose to access or use our Services, your visit, Use, and any dispute over privacy are subject to this Privacy Policy. Any disputes arising out of this Privacy Policy and the Services shall be governed by the laws of Delaware, and the courts of Delaware shall have exclusive jurisdiction. The proceedings shall be in English. For SMS Compliance Standards, we strictly adhere to: