ZUMO PTY LTD (ABN 677 038 809) (“ZUMO”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy. This Privacy Policy described how we collect and use your personal information when you visit our website (www.zumo.com.au) or use the Platform as described in the Terms of Service. The Privacy Policy is subject to and governed by the Terms of Service. Please read this Privacy Policy to understand our policies and practices regarding your personal information and how we will handle it. By accessing or using the Platform, you agree and consent to this Privacy Policy.
If you do not agree with this Privacy Policy, you should not accept them, create an account, or use the Platform.
All changes are effective immediately when posted. Your continued use of the Platform following the posting of any revised Terms constitutes your acceptance and agreement to the updated Privacy Policy.
ZUMO respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.
We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).
ZUMO may collect two types of information from you when you visit the Platform:
"Personal Information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.
“Non-Personal Information” means data that is about you but does not identify you specifically. If you do nothing during your visit to the Platform but browse, read pages, or view content, we will gather and store information about your visit that does not identify you personally.
“Customer Data” is the data that you input into the Platform about other people, including your customers. This information includes details about your customers including their names, email addresses, contact details, age, gender and other information that can reasonably identify an individual, either directly or indirectly.
You may contact us in writing at hello@zumo.com.au for further information about this Privacy Policy.
ZUMO will, from time to time, receive and store personal information you submit to our website, provided to us directly or given to us in other forms.
You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.
We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
Additionally, we may also collect any other information you provide while interacting with us. ZUMO will automatically collect information about how you interact with the Platform as you navigate through the Platform through the use of cookies, pixel tags, and similar technologies. Please view our separate Cookies Policy more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.
ZUMO collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.
By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.
We will primarily collect information:
(a) Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase, or request information from ZUMO, we will ask for things like your name, contact, billing, shipping and communication information, and account ID or credentials in order to fulfill your request.
(b) Directly from you about other people from your use of the Platform. If you input Customer Data or any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by You asking for their consent).
(c) From third parties. We obtain information through partners, vendors, suppliers and other third parties. The parties from whom we obtain information are typically corporate enterprises, and they may be located in any of the locations where we do business. These enterprises largely fall into the following categories: advertising and marketing companies, data set and information vendors, public database providers, social media platforms, partners, providers of products or services, hosts or vendors at events, research partners, or enterprises that use ZUMO’s services. We take steps to confirm that the information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us. This kind of data is used for work like improving the Platform and other ZUMO services, enhancing existing products and developing new capabilities and features. In some cases, we combine Personal Information about individuals that we receive from multiple sources, including directly collected from you or through your use of the Platform.
(d) Automatically as you navigate through the Platform or during the time in which you utilise our services. We collect information about how you interact with the Platform through the use of cookies, pixel tags, and similar technologies. Please view our separate Cookies Policy for more information on our use of cookies and similar technologies.
ZUMO may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services, and opportunities available to you.
ZUMO will use personal information only for the purposes that you consent to. This may include:
(a) For functionality and development of the Platform and ZUMO services. We use information to provide, offer, and personalise the Platform and other ZUMO services provided to you. Some information, like your IP address, is used to communicate with your device to provide network connectivity, measure usage levels of the Platform, diagnose server problems and provide security features. Other business purposes that depend on the use of your information include data analysis related to testing, modifying, improving, or developing new products, services and technologies and identifying trends. We use cookies to make our websites and the Platform operate, work more efficiently, and provide analytic information.
(b) For customer support, Platform updating and reporting. The Platform may use information to provide ZUMO with updates and reports and to check that the Platform is working properly. Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernised in order to provide you with the up-to-date security, versions, features, options and controls associated with your systems or devices. We rely on information to analyse performance and improve and maintain the Platform. We also rely on Personal Information you provide to us to provide you with customer support for the Platform and other ZUMO services, and to verify eligibility for promotional offers.
(c) To communicate. We use contact information to send messages; provide ZUMO services; respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and send marketing or informational materials like newsletters or white papers in accordance with your communication preferences. We occasionally conduct surveys or do focused research or studies that may require you to voluntarily share Personal Information in order to participate. These activities typically have additional notices that provide more information about the use of your Personal Information and to which you may be asked to consent.
(d) For advertising and marketing. We may use Personal Information collected from you, combined with information about what advertisements you viewed and other information we collect, to enable us to provide personalised content and to study the effectiveness of advertising and marketing campaigns. You may choose whether to allow or deny uses or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, we may not be able to provide you with certain personalised ZUMO services and content on the Platform.
(e) For statistical purposes to improve the Platform. We may compile Platform statistics into traffic reports, which help ZUMO understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the ZUMO Platform, we are likely to highlight that information on the Platform. This information helps us to create a better overall experience with Platform users.
If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.
We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.
We will only retain your Personal Information and Customer Data for as long as appropriate OR reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. In certain circumstances, you can ask us to delete your data (see below, “GDPR” and “Your Rights Under the GDPR”). In some circumstances, we will anonymise your Personal Information for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Where none of the above is applicable, ZUMO will delete and remove your Personal Information upon termination of the agreement.
The Platform is designed to provide reasonable and appropriate administrative, technical, and organisational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorised or unlawful access, use or disclosure.
ZUMO may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, licensors, or sub-processors insofar as reasonably necessary for the purposes set out in this privacy policy. When we share your Personal Information with these companies and parties, we put in place appropriate measures to limit the use of your information only for legal and authorised purposes that are consistent with this Privacy Policy, as well as appropriate confidentiality and security measures.
We may disclose your Personal Information that we collect or that you provide as described in this Privacy Policy:
(a) With affiliates and subsidiaries. For purposes limited to and consistent with this Privacy Policy
(b) With suppliers. Our authorised vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at ZUMO, and we process Personal Information using these tools as part of our regular course of business. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.
(c) With partners. We occasionally have relationships with third parties that are not suppliers or vendors but are working with us to offer certain opportunities such as marketing and similar promotions, to enable joint products or research studies, or to facilitate services on the Platform. In these cases, additional terms or Privacy Policies may be provided. For third parties or uses not described in this Privacy Policy, we share your information only with a lawful basis to do so.
(d) For advertising and marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalised ads and to study the effectiveness of your campaigns. In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform.
(e) For connections to social networks and third-party services. When you are using the Platform and have chosen to connect your social network profiles to ZUMO, or if you authorise a third-party service to access your account, you are agreeing to provide information about you to the social networks and the third-party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to ZUMO, this connection uses YouTube’s API services, and the Google Privacy Policy will apply to you. If you have authorised us to access your information via the YouTube API services, in addition to your normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page.
(f) Sales, mergers, and acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business assets or stock.
(g) With your consent. ZUMO may disclose your Personal Information to any other person or entity where you consent to the disclosure.
ZUMO will comply with the GDPR's principles of data protection to ensure fairness, transparency, and lawful data collection and use.
We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data we collect and how we use it.
We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose.
We will keep your data safe and secure. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
Under the GDPR, you have certain rights as to how your personal information is obtained and used. ZUMO complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
Except as otherwise provided in the GDPR, you have the following rights:
(a) to be informed how your personal information is being used;
(b) access your personal information (we will provide you with a free copy of it);
(c) to correct your personal information if it is inaccurate or incomplete;
(d) to delete your personal information (also known as "the right to be forgotten");
(e) to restrict processing of your personal information;
(f) to retain and reuse your personal information for your own purposes;
(g) to object to your personal information being used; and
(h) to object against automated decision making and profiling.
Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.
We may ask you to verify your identity before acting on any of your requests.
Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia.
The hosting facilities for our website are situated in the United States & IRELAND. Transfers to the United States & IRELAND will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from ZUMO's Data Protection Officer.
Our Suppliers, contractors and sub-processors are situated in the United States, United Kingdom, Germany, Ireland, Italy, France, Spain, Sweden, Switzerland, and India. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from ZUMO's Data Protection Officer.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
ZUMO is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant, or misleading, please email us at hello@zumo.com.au
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to hello@zumo.com.au We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.
17.1 When you visit our website When you come to our website (www.zumo.com.au), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
17.2 Cookies We may, from time to time, use cookies on our website. Cookies are very small files that a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may, from time to time, use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third-party services such as Google AdWords. These ads may appear on this website or other websites you visit.
17.3 Third-party sites Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that ZUMO is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each website that collects personal identifiable information.
Some browsers incorporate a “Do Not Track” (DNT) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.
This policy is effective from May 17th 2024.
