Privacy Policy

This Privacy Notice for Zulu Code (Pty) Ltd ('we', 'us' or 'our') describes how and why we might access, collect, store, use and/or share ('process') your personal information when you use our services ('Services'), including when you:

• visit our website at zulucode.co.za, or any website of ours that links to this Privacy Notice;
• ask us for a quotation, or engage us to design, build or host a website, app or software, or to register a domain;
• contact us by email, phone or WhatsApp; or
• engage with us in other related ways, including any sales, marketing or events.

We are the responsible party for your personal information under the Protection of Personal Information Act 4 of 2013 ('POPIA').

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@zulucode.co.za.

Summary of key points

This summary provides key points from our Privacy Notice. You can find out more about any of these topics by following the link after each key point or by using the contents above.

What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the services you ask us for. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We share information with the service providers that help us deliver our Services, and with domain registries when you ask us to register a domain. We do not sell your personal information. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Learn more about how we keep your information safe.

What are your rights? Under POPIA you have the right to access, correct and delete your personal information, to object to its processing and to complain to the Information Regulator. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at info@zulucode.co.za. We will consider and act upon any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you enquire about our Services, accept a quotation, work with us on a project, or otherwise when you contact us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the services you ask us for. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• your company name and billing details
• project information you share with us, such as briefs, brand assets and content
• where a project needs them, login details for your existing accounts, such as hosting, domain or app store accounts
• if you ask us to register a domain: the registrant details the domain registry requires

Sensitive information. We do not process sensitive personal information.

Payment data. If you pay us online, you enter your card details with our payment provider (PayFast or Paystack), which processes and stores them. We do not receive or store your full card number or security code; we receive only the result of each payment. You can find each provider's privacy notice on its website.

Information collected automatically

Device and log data. When you visit the Site, our hosting provider automatically records technical information such as your IP address, browser and device type, the pages you request and the time of your requests. We use it to keep the Site secure, to prevent abuse and to fix problems. We do not use advertising or analytics software on the Site, and we do not track you across other websites or apps.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Google Fonts

The Site uses fonts from Google Fonts. To display them, your browser connects to Google, which receives your IP address and browser details, and Google's privacy policy applies to that information.

Personal information in projects we build for you

A website, app or system we build, host or maintain for you may process personal information about your own customers, staff or users. For that information you are the responsible party and we are your operator under POPIA: we process it only with your knowledge or authorisation, only to deliver and support the Services you have asked for, and we keep it secure as sections 20 and 21 of POPIA require. Your own privacy notice tells those people how their information is used.

2. How do we process your information?

In short: We process your information to provide, improve and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To respond to enquiries and prepare quotations. We may process your information to reply to you and to prepare a proposal or quotation for the work you ask about.
• To provide the Services. We may process your information to design, build, launch, host and maintain the website, app or software you have engaged us for, and to register and renew your domains.
• To invoice you and take payments. We may process your information to issue quotations and invoices, take payments and manage recurring plans.
• To respond to user inquiries and offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with the Services.
• To send you updates. We may process your information to send you occasional updates, where you have opted in. You can unsubscribe at any time.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

In short: We only process your personal information when we have a valid legal reason to do so under POPIA.

Section 11 of POPIA lists the grounds on which personal information may be processed. We rely on the following:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose, such as sending you updates. You can withdraw your consent at any time.
• Performance of a contract. We may process your personal information when it is necessary to perform our agreement with you, including providing our Services, or to take steps at your request before entering into one, such as preparing a quotation.
• Legal obligations. We may process your information where it is necessary for compliance with our legal obligations, such as keeping tax and accounting records, cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
• Legitimate interests. We may process your information when it is reasonably necessary for our legitimate interests, or those of a third party to whom it is supplied, and those interests are not outweighed by your interests and rights. For example, to diagnose problems, prevent fraud and misuse, and keep the Services secure.
• Your legitimate interests. We may process your information where it protects a legitimate interest of yours, such as situations involving potential threats to your safety.

4. When and with whom do we share your personal information?

In short: We may share information in specific situations described in this section and/or with the following third parties. We do not sell your personal information.

We may need to share your personal information in the following situations:

• Service providers. We share information with vendors that process it on our behalf and only as needed to deliver the Services, under confidentiality obligations: website and application hosting (the Site is hosted by Netlify), email, and payment processing (PayFast or Paystack).
• Domain registries and registrars. When you ask us to register or renew a domain, we give the registry and registrar the registrant details they require. Some registries publish registrant details in their public WHOIS records under their own policies.
• WhatsApp. If you contact us on WhatsApp, WhatsApp (Meta) receives your phone number and messages under its own privacy policy.
• Legal requirements. We may disclose your information where we are legally required to do so, for example in response to a court order or a lawful request from a public authority.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company.

Transfers outside South Africa

Some of our service providers, including the host of the Site, process information in other countries. Where we transfer your personal information outside South Africa, we do so only as section 72 of POPIA allows: to countries with laws that provide an adequate level of protection, such as the European Union's General Data Protection Regulation, or under written agreements that require the recipient to protect your information to a standard substantially similar to POPIA.

5. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months after our last engagement with you ends, except invoices and accounting records, which we keep for as long as tax and company law requires.

When we have no ongoing legitimate business need to process your personal information, we will either delete or de-identify such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process, including encryption in transit. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

If we have reasonable grounds to believe that your personal information has been accessed or acquired by an unauthorised person, we will notify you and the Information Regulator as required by section 22 of POPIA.

7. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

The Services are only for people who are 18 or older. We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@zulucode.co.za.

8. What are your privacy rights?

In short: You have the rights POPIA gives you, and you can use them at any time.

Under POPIA you have the right to:

• ask whether we hold personal information about you, and request a copy of it;
• ask us to correct or delete personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, or that we are no longer authorised to keep;
• object, on reasonable grounds, to the processing of your personal information, and to object at any time to its use for direct marketing;
• withdraw your consent where we rely on it;
• not be subject to a decision based solely on automated processing that has legal consequences for you or affects you to a substantial degree; and
• complain to the Information Regulator.

To make a request, email us at info@zulucode.co.za. We may need to confirm your identity before we act on it. We will consider and act upon any request in accordance with POPIA and the Promotion of Access to Information Act 2 of 2000.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details provided in this document. This will not affect the lawfulness of the processing before its withdrawal, nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

The Information Regulator

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the Information Regulator (South Africa):

• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

9. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. We do not track you across other websites or apps, and the Site sets no cookies (see our Cookie Policy), so the Site behaves the same whether or not DNT is switched on.

10. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last updated' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

11. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@zulucode.co.za or contact us by post at:

12. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update or delete your personal information, email us at info@zulucode.co.za.

Back to top