Zlto Privacy Policy
Draft | Version 1.0
Last Updated: 1 April 2019
This is the main privacy policy for Zlto and it applies to all our Platforms. When we talk about our “Platforms” we refer to all our websites, mobile sites, mobile apps, emails, or any other technology or services you may use to interact with us.
We strive to provide you with a dynamic, interactive experience on all our Platforms. It is our aim to provide you with the best and most relevant possible experience. One of the ways we do this is by analysing information we collect and receive from you in order to personalise your experience across our platforms.
This privacy policy describes how we handle the information we collect and receive from you. By using our Platforms you are agreeing to the provisions of this privacy policy.


Information we collect and receive

We collect and receive information about you in the following ways:

1. Information you give us:

This includes any information that you provide to us directly, whether through our platforms, personal interaction, or via phone, SMS, or any other medium. This may include information you give to us:

• by filling in forms on our platforms. This may include actions such as signing-up on the platform or when you activate, subscribe, or register to use services on our platforms;


• when you enter a competition, promotion or complete a survey;


• by posting content or comments on our Platforms;


• when you share information during interaction with our staff;


• from documents your provide us;


• when you contact us and when you otherwise provide information directly to us.

2. Information we collect or receive when you use our Platforms or services

We collect information when you use our Platforms or services by using cookies, web beacons, and other technologies. Depending on how you access and use our Platforms, we may receive:

• Log information (for example information about your interactions with our Platforms and other services you use, the content you view, courses you complete, jobs advertisements you view, and the search queries you submit);


• Information we infer about you based on your interaction with our Platforms and services


• Device information (for example the type of device you’re using, how you access our Platforms, your browser or operating system, and your Internet Protocol ("IP") address);


• Location information (for example, your device’s GPS signal and information about nearby WiFi networks and cell towers. We get this information when you use location-enabled services).

How we use the information we collect and receive

We use the information we collect and receive for the following general purposes:

To provide you with information or services you request from us.

• To communicate with you. We may want to notify you about changes to our Platforms or provide you with information about services, job opportunities, courses, that we feel may interest you.


• To be effective and relevant in the services we provide you. We want to ensure we present you with content and services from our Platforms that are relevant and engaging. We also want to ensure we deliver it in a way that is appropriate to the device you are using, your location, and data we have collected and received that describes you.

How we share the information we collect and receive

We don’t sell your personal information to third parties.
We may share information with:

• Our affiliates, in other words, partners in the RLabs group of partners (www.rlabs.org) consists of a number of different companies that all collect customer information. By sharing this information amongst business units, we may learn more about our beneficiaries, allowing us to create a more relevant and engaging experience.
  Business partners, donors, and sponsors. We may share non-personally identifiable information with select business partners. This means that we do not disclose information about identifiable individuals to our business partners (in other words, we do not give them your name and contact details), but we may provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 20 have volunteered in their communities).


• Other parties in response to legal process or when necessary to conduct or protect our Platforms. We may disclose your information if we are under a duty to disclose or share your information in order to comply with any legal obligation or to protect our Platforms. We may also disclose your information during the process of debt collection, or to our attorneys in connection with any potential, threatened or actual litigation, or to our auditors for the purpose of auditing our accounts.


• Other parties in connection with certain business transactions. In the event that we hand over responsibility for the operation of the Platforms to another party, we may disclose your personal information to the prospective buyer of such business or assets.


• Companies that provide services to us. Companies that provide services to us or act on our behalf may have access to information about you. These companies are limited in their ability to use information they receive in the course of providing services to us or you.


• Third-parties where you provide consent. In some cases, third-parties may wish to attain information about you in order to promote their products to you, or for whatever other reason. We may share information with third-parties where you provide consent in the form of explicit opt-in. Such circumstances may include (but are not limited to) an entry into a competition sponsored by a third-party where the provision of your information is a condition for entry to the competition, or where you express your interest in a product or service for which you would like more information. We will also ensure that your opt-in is explicit and that we provide a clear description of what data would be shared with the third-party. Remember that once you have opted in to allow us to send your information to the third-party, we cannot control what they do with your data; therefore, be sure to investigate their privacy policies before providing permission for us to share your information.


• Other parties that provide content, services, or functionality on our Platforms. Some of the content, services, and functionality on our Platforms may be provided by third parties that are not affiliated with us. Such third parties include: Audience-measurement companies, which help us measure the overall usage of our Platforms and compare that usage to other online services; and social networking services (like Facebook, Twitter, LinkedIn, Instagram) that enable you to register and log into certain of our services and to share things you find on our Platforms with your social network. This is only applicable if you choose to connect with a social networking service; we may provide other registration and login methods. These third parties may collect or receive information about your use of our Platform, including through the use of cookies, web beacons and other technologies, and this information may be collected over time and combined with information collected on different websites and online services. It’s important to remember that we don’t control the privacy practices of these (or any other) third-party services. So we encourage you to read the privacy policies of these services before connecting to them

You have the right to ask us not to contact you for promotional purposes. You can exercise this right at any time by using any of the various “opt-out” options that we will always provide to you when we communicate with you. We manage a number of separate distribution lists across our Platforms, each having its own theme and purpose. By opting out of one distribution list, does not automatically remove you from all other lists. You cannot opt-out of routine service correspondence from us, because then we would not be able to provide services to you.


Our Platforms use cookies. If you wish to reject our cookies, you can configure your browser to do so. A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our Platforms. It enables our own system to recognise you when you visit our Platforms again and improve our service to you. Cookies may also be used to compile aggregate information about areas of our Platforms that are visited most frequently. This traffic information can be used to enhance the content of our Platforms and make your use of it easier.


Our commitment to security

Although no one can guarantee the security of the information collected and received, we do employ a number of safeguards intended to mitigate the risk of unauthorised access or disclosure of your information. We will do our best to protect your personal information and we will use up to date technology that will help us to do this.


Links to other websites

Our Platforms contain links to and from websites, mobile applications or services of third parties, advertisers or affiliates. Please note that we are not responsible for the privacy practices of such other parties and advise you to read the privacy statements of each website you visit which collects personal information.


International users

Zlto is based in South Africa, and, regardless of where you use or access our Platforms, products, or services, your information may be transferred to and maintained on servers located in South Africa (or elsewhere in the world). Please note that any information we obtain about you will be stored in accordance with South African privacy laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using our Platforms you consent to this collection, transfer, storage and processing of information to and in South Africa.


Changes to this privacy policy

We may update this privacy policy from time to time. Any changes we may make to our privacy policy will be posted on this page and, where appropriate, notified to you in the appropriate manner.


Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@zlto.co


Article 27: EU Representative.

EU representative for EU citizens is being undertaken by RLabs UK, https://www.rlabsuk.org/privacy-policy