Effective Date: August 1, 2023.
Introduction.
This Privacy Policy describes how Zulu Alpha Kilo Corp ("Zulu," "we," "our," or "us") collects, uses, and discloses information about you as well as your choices regarding such information. For purposes of this Privacy Policy, unless otherwise stated, "information" or "personal information" means information relating to an identified or identifiable individual, and does not include aggregate information or information that does not identify you.
This Privacy Policy applies to information we collect where we control the purposes and means of processing. Specifically, it applies to information we collect through any of our websites, emails, and other online services that link to this Privacy Policy (the "Service"). It does not apply to information collected by third parties or information collected in the context of your employment with us.
Please note that your use of the Service is subject to our Terms of Use.
For our contact details, see the Contact Us section below.
How We Collect Information.
We collect information about you in a variety of contexts, as described below.
Information You Provide through the Service.
When you use the Service, you may be asked to provide information to us, such as when contact us. The categories of information we collect include:
Contact Identifiers, including your email address.
Please do not provide any information that we do not request.
Information from Your Browser or Device.
When you use the Service, we and third parties we work with automatically collect information from your browser or device. The categories of information we automatically collect include:
Device identifiers, including your device's IP address.
Device information, including your device's operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, time of day you browse, and referring and exiting pages.
Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.
This information is automatically collected through cookies and other tracking technologies incorporated into our Service, as described below:
Cookies. Cookies are small text files which are placed on your browser when you visit a website, open or click on an email, or interact with an advertisement. Our Service uses session cookies (which expire when you close your browser) and persistent cookies (which expire at a set expiration date or when you manually delete them). We incorporate both first party cookies (which are cookies served directly by us) and third party cookies (which are cookies served by third parties we work with). We use cookies for a variety of purposes, including to help make our website work, personalize your browsing experience, prevent fraud and assist with security, perform measurement and analytics, and provide advertising.
Pixels. Pixels (also known as web beacons) are code embedded within a service. There are various types of pixels, including image pixels (which are one-pixel transparent images) and JavaScript pixels (which contain JavaScript code). Pixels are often associated with cookies and are used for similar purposes. When you access a service that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser, or collect other information about your browser or device.
App technologies. App technologies are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include Software Development Kits (SDKs), which are pieces of code released by third parties that provide certain functionality. App technologies are used for purposes similar to cookies and pixels, and may permit us or a third party to collect information from your browser or device.
For details on your choices around cookies and other tracking technologies, see the Your Privacy Choices section below.
Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
Business partners that offer co-branded services or engage in joint marketing or promotional activities.
Third party vendors and related parties we work with in connection with receiving analytics, security, and fraud prevention services.
Social media platforms with which you interact. For example, when you "like," "follow", or otherwise engage with our content on social media (such as through our brand page or direct message), we may collect information such as your contact identifiers and any comments you provide. If you publicly reference our Service on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Service.
Data providers, such as licensors of private and public databases.
Public sources, including where information is in the public domain.
Information We Infer.
We infer new information from other information we collect including to generate information about your likely preferences or other characteristics.
Sensitive Information.
To the extent any of the categories of information we collect are sensitive categories of information under applicable law, we process such information only for the limited purposes permitted by applicable law. We do not sell or use sensitive categories of information for purposes of targeted advertising or to make inferences.
How We Use Information.
We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:
Providing services. We use information to provide services to you, including to operate the Service and provide support.
Personalizing your experience. We use information to personalize your experience and show you content we believe you will find interesting.
Communications. We use information to communicate with you about updates, security alerts, changes to policies, and other transactional messages. We also use information to personalize and deliver marketing communications to you. Communications may be by email.
Analytics. We use information to understand trends, usage, and activities, for example through surveys you respond to and tracking technologies that we incorporate into the Service (such as Google Analytics). We also use information for research and development purposes, including to improve our services and make business and marketing decisions.
Promotions. When you voluntarily enter a promotion, we use information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law. By entering a promotion, you agree to the official rules that govern that promotion, and that, except where prohibited by applicable law, we, the sponsor, and related entities may use your name, voice and/or likeness in advertising or marketing materials.
Security and enforcement. We use information to prevent, detect, investigate, and address fraud, breach of policies or terms, or threats or harm.
At your direction or with your consent. We use information for additional purposes where you direct us to use it in a certain way or with notice to you and your consent.
Sometimes we aggregate or de-identify information so it is no longer considered personal information. We may use non-personal information for any purpose to the extent permitted by applicable law. For details on your choices around use of your information, see the Your Privacy Choices section below.
How We Disclose Information.
We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include:
Service providers. Many of the third parties we work are service providers that collect and process information on our behalf. Service providers perform services for us such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers from processing information they collect on our behalf for purposes other than performing services for us, although we may permit them to use non-personal information for any purpose to the extent permitted by applicable law.
Business partners. We disclose information to our business partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing or promotional activities.
Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers subject to this Privacy Policy or use the information in accordance with their own privacy policies.
Recipients in a merger or acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Recipients for security and enforcement. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
Recipients at your direction or with your consent. We disclose information where you direct us to or with notice to you and your consent.
Sometimes we aggregate or de-identify information so it is no longer considered personal information. We may disclose non-personal information for any purpose to the extent permitted by applicable law. For details on your choices around disclosure of your information, see the Your Privacy Choices section below.
Third Parties.
We may link to or offer parts of our Service through websites and services controlled by third parties. In addition, we may integrate technologies, including those disclosed in the How We Collect Information section above, controlled by third parties. Except where third parties act as our service providers, they, and not us, control the purposes and means of processing any information they collect from you, and you should contact them directly to address any concerns you have about their processing. Third party data practices are subject to their own policies and disclosures, including what information they collect, your choices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use. An example of where you may interact with a third party includes hyperlinks to third party websites and services.
Your Privacy Choices.
We provide a variety of ways for you to exercise choice, as described below.
Emails. You can opt-out of receiving emails by following the unsubscribe instructions near the bottom of such emails, or by emailing us at as set out in the Contact Us section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
Browser and Device Controls.
Cookies and pixels. You may be able to manage cookies through your browser settings. When you manage cookies, pixels associated with such cookies may also be impacted. Please note that cookie management only applies to our website. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings. Your ability to limit cookies is subject to your browser settings and limitations.
Preference signals. Your browser or extension may allow you to automatically transmit Do Not Track and other preference signals. Except as required by law, we do not respond to preference signals.
Third party opt-out tools. Some third parties we work with offer their own opt-out tools related to information collected through cookies and pixels. To opt out of your information being used by Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. We are not responsible for the effectiveness of any third party opt-out tools.
Industry opt-out tools for targeted advertising. Some of the third parties we work with participate in programs that allow you to opt-out of receiving targeted advertising from participants. To opt-out of receiving targeted advertising from participants of the Digital Advertising Alliance ("DAA") on your browser, visit https://www.aboutads.info/choices. To opt-out of receiving targeted advertising from participants of the Network Advertising Initiative ("NAI") on your browser, visit https://www.networkadvertising.org/choices/. If you choose to opt-out of targeted advertising through these links, you should no longer see targeted advertising from the selected participants on the browser or device from which you opted-out, but the opt-out does not mean that the participants will not process your information for targeted advertising purposes or that you will not receive any advertising. We are not responsible for the effectiveness of any third party opt-out tools.
Children.
The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us as set out in the Contact Us section below. We will delete the personal information in accordance with COPPA.
Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
Retention.
We retain information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
International Transfer.
We are based in the U.S. If you are located outside the U.S., please be aware that your information may be transferred to and processed in the U.S. or another country where we operate.
Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide additional notice to you, such as through email or prominent notice on the Service.
Contact Us.
If you have any questions about or trouble accessing this Privacy Policy, please contact us:
By email: hello@splashspots.xyz
By mail: Zulu Alpha Kilo Corp, 109 N 12th St, 9th floor Brooklyn, New York 11249
To exercise choice, use the methods described in the Your Privacy Choices section above or your region-specific terms below.
FKKS:3712808v.1 32961.100