ZULAMA, Inc, PRIVACY POLICY

May 13, 2010

At Zulama, Inc (“Zulama”) we know that online privacy is important to our customers and you have a right to know how information we collect through the Zulama Learning Management System (“Zulama LMS”) will and will not be used.

We have created this privacy policy in order to demonstrate our firm commitment to privacy by helping you understand what kind of information we collect through the Zulama LMS as well as how we collect and use your information.

This policy contains important information that impacts our use of your personal data. Please read this policy carefully. Use of the Zulama LMS is absolutely conditioned upon reviewing, understanding and agreeing to all of the information, disclosures and disclaimers contained in (1) this Privacy Policy; (2) the Zulama Terms of Use; and (3) the Subscription Agreement you or your school has entered into with Zulama.

Your Privacy

We do not collect or use Personal Information (as described below) about you except as discussed in this Privacy Statement.  We use your Personal Information for our internal purposes only. Those purposes include tracking the number and kinds of visitors to the Zulama LMS, analyzing the performance of the Zulama LMS, and tracking user preferences for internal marketing purposes as described more fully below. We do not sell, share, or intentionally make available to third parties or the general public your Personal Information.

Although it may be necessary for you to provide Personal Information to us to take advantage of our products or services or features of the Zulama LMS, we will always respect your request that we not use your Personal Information to send you promotional materials or otherwise use or disclose your information to anybody. Simply check the “opt out” box when you create your account. By using the procedures outlined below, you will also always have the opportunity to correct or change any of the Personal Information you provide to us, including changing your decision as to whether or not you would like us to use your Personal Information to provide information on products or services that may be of interest to you.

As used in this Privacy Statement, “Personal Information” includes one or more of the following types of information:  name, email address, physical address, student ID, age and similar unique, personal information that could identify you.

Disclosures

Account Information. When you create your account with us, we require you to provide certain Personal Information including your name and email address. We use your Personal Information to contact you directly when necessary. We also use your Personal Information to send you information about Zulama and promotional material about our products. You may opt-out of receiving future mailings; see the choice-opt-out section below.

Identifying Information.  Unique identifiers (such as names, user names or passwords or e-mail address(es)) are collected to verify the user’s identity, for use as account numbers in our record system, and for other verification purposes.

Templates

In order to utilize our services, Authorized Users will be asked to complete profiles by uploading certain personal data (as described in, and governed by, the Zulama Terms and Conditions of Use, the “User Content”). “User Content” also includes commentary you may elect to upload to annotate or further elaborate on information about yourself. Zulama collects and processes such data and, according to account preferences that you may set and adjust from time to time, may make such data available, in individually identifiable, non-individually identifiable and/or aggregated form as you may so direct. User Content released according to your stated preferences may be viewed by your designated users in response to applicable searches, queries and other data reports generated through the Zulama LMS Services.  You may set preferences in your profile regarding whether your profile information is visible to other users. Regardless of your stated preferences, Zulama may always use, process and disclose your User Content to other users and third parties on an aggregated basis without specifically identifying you (or your company or organization).  We may do this for purposes of aggregating the number of users in a given market, geographic area or other aggregated circumstances. Additionally, Zulama shall process, track and use such User Content to improve and provide services over the Zulama platform including without limitation, presentation of targeted purchase or sale opportunities; provided, no individually identifiable data will be disclosed by Zulama in furtherance of such efforts unless you respond or otherwise provide consent to such disclosure.  Zulama may occasionally use your User Content, name and email address to send you targeted and nontargeted notifications regarding new and other services offered by Zulama that we think you may find valuable. You shall have the opportunity to set your preferences with respect to such Zulama communications at the time you register and may elect to change such preferences in your profile; however, Zulama reserves the right to send you notices about your Zulama account and Zulama services even if you opt out of all voluntary email notifications.

We may be required to disclose your user information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We do not reveal information until we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards.

Additionally, we may share account or other information when we believe it is necessary to comply with law, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Zulama service or using the Zulama name, or to prevent imminent bodily harm. This may include sharing information with other companies, lawyers, agents or government agencies.

Traffic Data

In addition to “Personal Information” that you voluntarily provide, the Zulama LMS also gathers data generated automatically by traffic to the Zulama LMS (“Traffic Data”). For example, we use your computer’s IP address to help diagnose problems with our server, and to administer the Zulama LMS.  Your IP address is used to help identify you and to gather broad demographic information.

The Zulama LMS uses “cookies” to provide customer efficiencies such as automatically filling in standard information on return visits.  “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive.  Most web browsers automatically accept cookies, but they also allow you to configure your web browser to refuse cookies or to notify you before a cookie is set.  You can manually view (and delete) any cookies stored on your computer.  You will need to enable cookies in order to use Zulama—it’s best-practice to track user sessions using cookies.

Links

The Zulama LMS may provide hyperlinks to other sites on the Worldwide Web. The other sites so linked may or may not have been reviewed by us and are maintained by third parties over which we exercise no control. We expressly disclaim any responsibility for the i) content or accuracy of information contained on such linked sites; ii) quality of any product or service provided by or advertised by any linked site, and iii) the privacy practices or the content of such web sites. We neither endorse nor make any representation regarding any linked site and we advise you to check the privacy policies of such other sites.

Security

When you access your account information, we offer the use of a secure server. The secure server software (SSL) encrypts all information you input before it is sent to us.  Furthermore, all of the customer data we collect is protected against unauthorized access.

Commitment to Child Privacy

Protecting the privacy of children is very important to Zulama.  Zulama does not collect or maintain information from the Zulama LMS from those known to be under 13 years of age. No part of the Zulama LMS is designed to attract anyone under the age of 13.

Choice/Opt-Out

The Zulama LMS provides you with the opportunity to opt-out of receiving communications from us in your profile. If you wish to remove your Personal Information from our database and/or to not receive future communications, send an email containing your request to info@Zulama.com.

Correct/Update

The Zulama LMS gives users the following options for changing and modifying Personal Information previously provided:

  1. send an email containing your request to info@Zulama.com
  2. update or change information related to your account in your user profile.

Contacting Zulama

If you have any questions about this privacy statement, the practices of the Zulama LMS, or your dealings with the Zulama LMS, you can send an email containing your question(s) to info@Zulama.com.