Your Privacy Matters

At Zulleon, we respect your privacy and personal information.  This is the policy we follow when you entrust it to us.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; or (4) when we reasonably believe it is required by law.  We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our website.  If you object to any changes, you may close your account.  Continuing to use our services after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

  1. What Information We Collect

    1. Data Controllers

      Regardless of where you reside, the personal information provided to or collected by us is controlled by Zulleon Limited, 40 Dame Street, Dublin 2, Ireland.  If you have any concern about providing information to us or otherwise used in any manner permitted in this Privacy Policy, you should not use our services.

    2. Registration

      To gain access to the OOKS virtual world or make an in-app purchase, you must provide us with the your name, email address, a contact telephone number and a postal address as well as basic information about your child such as name, age, gender, spoken language and some simple personal preferences, all of which are designed to ensure that each child enjoys a highly personalized play experience when engaging with us.  We will also ask for your credit card details if you wish to make a subscription or purchase.

    3. Customer Service

      We also track your and your child’s engagement with our website to better enable us to track potential problems and trends and customize our support responses to better serve you.  We do not use this information in advertising.

      We collect information when you or your child uses our website, applications, our platform technology or other services.  For example, we collect information when you view or click on ads on and off our services, perform a search, join and participate in groups, participate in polls, install one of our mobile applications, view or share content.

    4. Using Third-Party Services and Visiting Third-Party Sites

      You allow us to receive information when you use your account to log in to a third-party website or application. You also allow us to receive information about your visits and interaction with the sites and services of our partners that include our cookies and similar technologies, unless you opt out.  If you are not a subscriber, we rely on the online terms between you and our partners.

    5. Cookies

      We use cookies and similar technologies, including mobile application identifiers, to help us recognize you across different services, learn about your interests, improve your experience, increase security and measure effectiveness of our services. You can control cookies through your browser settings and other tools.  By visiting our website, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Privacy Policy.

    6. Advertising

      We do not share your personal information with any third-party advertisers or ad networks for advertising without your separate permission.

      We may invite you to view sponsored content on or via our website that will be designated as sponsored content.  If you take social action (for example, if you “like” or “comment” on the sponsored content), your action may be seen by others who are shown the sponsored content after you have acted on it.

      If you do not wish to receive targeted ads from most third party companies, you may opt-out.  Please note this does not opt you out of being served advertising.  You will continue to receive generic ads or targeted ads by companies not listed with these opt-out tools.  You can also opt out specifically from our use of cookies and similar technologies to track your behaviour on third party sites.

    7. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

      When you visit or leave our website (whether as a subscriber or visitor) by clicking a hyperlink or when you view a third-party site that includes cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed.  Also, advertisers receive the URL of the page that you are on when you click an ad on or through our services.  We also receive the internet protocol (“IP”) address of your computer operating system details your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are using a mobile device), and the name of your ISP or your mobile carrier.  We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show your local information on our mobile applications and for fraud prevention and security purposes.  Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honour your settings.

      In the case of Android apps, you will be provided notice of the types of data (e.g. location) that will be sent to us.  If you choose to use our app after this notice, we process this data to enable registration or preview product features for you.  If you choose not to become a member, we will delete this information.

    Other

    We will always keep abreast of new ways to optimize your and your child’s enjoyment when interacting with us and this may include new features, some of which may result in the collection of new information.  If this results in new types of personal information and materially changes how we handle your data, we will modify this Privacy Policy and notify you.

  2. How we Use Your Personal Information

    You agree that information you provide on your profile can be used by us as described in this Privacy Policy.

    We communicate with you using email, and other ways available to us including mobile text messages.  We may send you messages relating to the availability of our services or security issues.  We also may send promotional email messages to you.  You can change your email and mobile device settings at any time.  With certain communications you send on our services, the recipient can see your name, email and postal address.

    1. Consent to our Processing Information About You

      The personal information that you provide to us may reveal or allow us to identify aspects of your family life that are not expressly sought when you subscribe.  By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily agreeing to our processing of your personal information in ways set out by this Privacy Policy.  Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part.  You can withdraw or modify your consent to our collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy.

    2. Communications

      We communicate with you through email and notices posted on our website.  Examples of these communications include (a) welcome and engagement communications – informing you about how best to use our services, new features, updates and other members and their actions; (b) service communication – these will cover service availability, security and other issues about the functioning of our services; (c) promotional communications – these include both email text messages.  These messages will be sent to you based on your profile information and messaging preferences.  We track the open rate of our emails to you.  You may change your email and contact preferences at any time.  You can also opt out of promotional messages.

      Please be aware that you cannot opt out of receiving service messages from us.

    3. Service Development; Customized Experience

      We use the information and content that you and other subscribers provide to us to conduct research and development for the improvement of our services in order to provide you and other members and visitors with a better, more intuitive experience and drive membership growth and engagement on our services.

    4. Sharing Information with Third Parties

      We do not rent or sell or otherwise seek to exploit for commercial gain any personal information that you have entrusted to us.

    5. Polls and Surveys

      We conduct our own surveys and polls and also help third parties do this type of research.  Your participation in surveys or polls is up to you.  You may also opt out of getting invitations to participate in surveys.

    6. Groups

      If you participate in user groups, share content on your network update stream, or import a blog or other content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other members in these forums by developers and other third parties, including advertisers.  We are not responsible for the information you choose to submit in these forums.  User group contributions are typically searchable on our services and some content in groups may be public and searchable on the Internet if the group is open for public discussions.  You can identify whether groups are open or closed before you participate. You can remove your posts at any time.  However, others may have copied and used the information that you shared.

    7. Testimonials

      If you provide any testimonials in connection with the promotion of our services to third parties, these will be shared with third parties but we will not include your name and other personal information without your consent.

    8. Compliance with Legal Process and Other Disclosures

      It is possible that we may need to disclose personal information, profile information, or information about your activities as a subscriber or visitor when required by law, subpoena, or other legal process, whether in Ireland or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected ore actual illegal activities or to assist government enforcement agencies; (b) defend ourselves against any third-party claims or allegations, or protect the security or integrity of our services; or (c) exercise or protect the rights, property, or safety of Zulleon, our members, personnel, or others.  We attempt to notify subscribers about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency.  In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand.

    9. Disclosure to Others as the Result of a Change in Control or Sale of Zulleon Limited

      We may also disclose your personal information to a third party as part of a sale of the assets of Zulleon Limited, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for these events.  Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

    10. Service Providers

      We may employ third party companies and individuals to facilitate our services (e.g. maintenance, analysis, audit, marketing and development).  These third parties have limited access to your information only to perform these tasks on our behalf and are obliged not to disclose or use it for other purposes.

    11. Data Processing Outside Your Country

      We may transfer your information and process it outside your country or residence, wherever Zulleon Limited and its service providers operate.

  3. Rights to Access, Correct or Delete Your Information and Closing Your Account

    You have a right to (a) access, modify, correct, or delete your personal information controlled by us regarding your profile, (b) change or remove your content, and (c) close your account.  If you close your account, your information will generally be removed within 24 hours.  We generally delete closed account information and will de-personalize any logs or other backup information through the deletion process within 30 days of account closure.

    1. Data Retention

      We retain the personal information you provide while your account is in existence or as needed to provide you services.  We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy Policy.  We may retain personal information, for a limited period of time, if requested by law enforcement.  Our Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data.

  4. Important Information

    We comply with the U.S. E.U. and U.S. Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland.  We have certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement

    We may change this Privacy Policy from time to time.  If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the services or by some other means, such as email.  Please review the changes carefully.  If you agree to the changes, simply continue to use our services.  If you object to any of the changes to our terms and you no longer wish to use our services, you may close your account(s).  Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.  Using our services after a notice of changes has been communicated to you or published on our website shall constitute consent to the changed terms or practices.

    Since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us.  These is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.  It is your responsibility to protect the security of your login information.  Please note that emails, instant messaging, and similar means of communication with other members are not encrypted, and we strongly advise you not to communicate any confidential information through these means.  Please help keep your account safe by using a strong password.