Privacy Policy

At AskLulo, we respect your privacy. Our Privacy Policy confirms that your information belongs to you: we won’t sell it to anyone, nor will we use it to spam you. Here is our Privacy Policy in full.

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AskLulo is committed to the privacy of your Personal Information. Your information is yours - always. We will always collect the minimum amount of Personal Information necessary to provide the Service to you. Our staff and Authorised Service Providers are bound by confidentiality and privacy obligations that align directly with this Privacy Policy. They are given access only to the information they require to fulfill their responsibilities.

This Privacy Policy describes and explains what Personal Information we collect, how we use it, and how we protect it. "Personal Information" means any information that is recognised as such under South African Law and includes any information which identifies you (our customer) or which, when linked to other information, can personally identify you.

AskLulo collects information from the following platform user types:

• Clients

A user that holds an account with AskLulo and either directly creates campaigns,  forms, applications, or questionnaires for a user that is collaborating on, commenting on, or reviewing campaigns, forms, applications, or questionnaires within an account.

• Consumers

A user that has engaged with a  campaign,  form, application, or questionnaire powered by the AskLulo service.

• Business website visitor

Someone just visiting one of our Client websites because they are curious, or you have heard about us from our marketing and sales channels.

• Consumer website visitor

Someone just visiting one of our consumer websites because they are curious, or you have heard about us from our marketing and sales channels!

Information collected from AskLulo platform users in general:

• Contact Information (for example name or email address).

Users might provide us with their contact information, whether through the use of our services, a form on our website, an interaction with our sales or customer support team, or a response to one of AskLulo's own campaigns.

• Usage information.

We collect usage information about users whenever they interact with our websites and services. This includes which web pages they visit, what you click on when you perform those actions, what language preference they have, what they buy, and other related website activity metrics.

• Device and browser data.

We collect information from the device and application users use to access our services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type. If users are on a mobile device we also collect the UUID for that device.

• Log Data.

As is custom for most modern websites, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type, and timestamps.

• Referral information.

If a user arrives at the AskLulo website from an external source (such as a link on another website or in an email), we record information about the source that referred the user to us.

• Information from third parties and integration partners.

We collect your personal information from third parties where, for example, users gave permission to those third parties to share user information with us or where the user has made that information publicly available online. We will only obtain the information required to fulfill the intended actions.

• Correspondence Information

Information we collect when we receive correspondence from users via email, social media, mobile text messages, and phone calls. This includes user sender information, the content of the message, and the metadata pertaining to the message. We use this information to communicate with users and to improve AskLulo.

Specific Client information collected:

• Registration information.

Clients need an AskLulo account before they can use AskLulo services. When they register for an account, we collect their first and last name, username, company, password, and email address.

• Billing information.

If a client makes a payment to AskLulo, we require Clients to provide their billing details, a name, address, email address, and financial information corresponding to their selected method of payment.

• Account settings.

Clients can set various preferences and personal details on pages like their account settings page. For example, opting in or out of receiving marketing communications from AskLulo.

• Consumer information

Clients may import email addresses and other contact information to easily invite people to take surveys. We do not use this data for our own purposes or contact anyone, except with their consent.

• Survey/form/application data.

We store user campaign/form/application data (questions and responses) for Clients and provide analysis tools for them to use with respect to this data.

• Profile information

When Clients sign up for our services, they are asked to provide us with information about themselves and to give us more detailed insights into who they are. This typically entails demographic and employment status information

Consumer information collected:

• Cookies

We collect information using cookies when Consumers engage in a campaign. These cookies are used to ensure that the full functionality of our Campaign service is operational, and to ensure the campaign operates appropriately and optimally.

• Contact Information

We only use contact information to respond to an inquiry which Consumers submit to us, and as a potential avenue to reward Consumers or keep them informed of any processing of personal information.

• How consumers use our services

We use information about how Consumers interact with our services to improve services for all users.

• Device and browser data

We use device data both to troubleshoot problems with our service and to make improvements to it. We also infer consumer geographic location based on your IP address.

• We log data

To monitor abuse and troubleshoot. To create new services, features, content, or make recommendations. To track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our services. To fix bugs and troubleshoot product functionality.

• Third parties and integrations

We will collect and use information from third parties and integration partners to facilitate Clients in sending campaigns/forms/applications/questionnaires/rewards to consumers.

• Machine learning

We will use machine learning techniques on response data, metadata (as described above), and cookie data, in order to provide Clients with useful and relevant insights from the data they have collected using our services, to build features, improve our services, for fraud detection and to develop aggregated data products. Data will be used at an aggregate level and anonymized during use.

• To manage our services, we will also internally use your information and data
• To enforce our agreements where applicable.
• To prevent potentially illegal activities.
• To screen for and prevent undesirable or abusive activity.
• For example, we have automated systems that screen content for phishing activities, spam, and fraud."
• Legal uses

To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about Clients or consumers as may be required. If we receive a legal request, we may need to inspect the data we hold to determine how to respond.

• Use of consumer responses

In general survey responses to AskLulo, surveys are controlled and managed by the Client (the person who sent or deployed that survey). In those instances, AskLulo is only processing those responses on behalf of the Client.

Client and Consumer trust is paramount to everything we do and so when we do use data about Consumers, we put Clients and Consumers first. When we do an analysis of response data we only do so once we have ensured the anonymity of individual consumers (by aggregating and anonymizing the data).

Our goal is to improve the user experience across AskLulo survey services while maintaining the confidentiality and privacy of responses.

We will aggregate responses, activity, and behavior of consumers so that we can identify trends, build product features that optimize responses, make product recommendations and provide guidance on which products and services work best in different scenarios. These product features also provide feedback and recommendations to increase response rates. Aggregated and anonomised demographics elements will be added to the survey results.

• Usage patterns

By understanding response data and Consumers interactions in different types of surveys we can:

• Improve our services and ease of use: for example, we might identify when respondents prefer multiple choice versus open text questions and make predictive response suggestions when certain question types are selected. We might also use this data to help improve the analysis of responses,
• Undertake personalization for survey Clients and Consumers (for example by customizing the page on our website that a Consumer sees at the end of a survey.

• Improve user experience (for example, by collecting and using device and browser information from Consumers to improve how our survey service operates on those devices and in those browsers), and

• Identify insightful data trends (which will never identify any individuals).

Information shared by users

• Many of our services let users share information with other responsible parties.

When users share information publicly, it can be indexable by search engines. Our services provide users with different options for sharing and deleting their content but we cannot delete content from search engines so users need to be careful about the information they make public.

Information AskLulo shares

• We do not share user information or data with third parties outside AskLulo except in the following limited circumstances:

• If a Client is part of an Enterprise plan using AskLulo, their account information and data will be shared with the primary administrator(s) on the Client side and their campaign data may also be visible to other members in their team with whom they share their surveys or with whom they collaborate. Client administrator(s) will be able to view their account data, change their passwords, suspend, transfer or terminate their account or restrict their settings. Please refer to your organization’s internal policies if you have questions about this.

• To help AskLulo provide certain aspects of our services we use our affiliates and trusted key partners – in particular, we engage third parties to:

• Facilitate our Clients campaigns for reaching their current or potential customer base by email, text or WhatsApp to Consumers. We share the relevant contact information for respondents (email address or phone number as applicable) with these third parties.
• Facilitate Clients in making payments and/or detect fraudulent payment attempts.
• Deliver and help us track our marketing and advertising content.
• Help us track website conversion success metrics.
• Manage our sales and customer support services to you, including resolving any disputes.

• We enter into confidentiality and data processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.

• On Client instructions, we share your selected information or data if you choose to use an integration in conjunction with AskLulo services, to the extent necessary to facilitate that use.
• We also may have to share information or data in order to:
• Meet any applicable law, regulation, legal process, or enforceable governmental request.
• Enforce applicable policies, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security, or technical issues.
• Protect against harm to the rights, property, or safety of our users, the public, or to AskLulo and/or as required or permitted by law.
• Facilitate a sale, merger, or change in control of all or any part of our company or business or in preparation for any of these events.
• When we use any third parties to assist us in service delivery for Clients, and they process consumer data as part of that service, we provide a list of these third parties which is available on request. This contains a list of all sub-processors used across all services covered by this Privacy Policy so please keep in mind that your service may only be impacted by a subset of these sub-processors.

• AskLulo will not sell any personal user information, unless with express consent from the consumer.

AskLulo collects and uses personal information only to provide the Service to users and as set out in this Policy.

Data retention and aggregation

• AskLulo is the owner of the tools used to build campaigns and analyze data. Whom we regard as the owner of a Client account and the data in it depends on the Clients plan type.

If a Client holds an account with AskLulo we do not delete the data in their account – Clients are responsible for and control the time periods for which they retain this data. There are controls in the Client account where they can delete data at the account level (all data in their account) and at the response level.

We may aggregate and analyse user 'de-identified' information (i.e. stripped of all uniquely identifiable attributes and that cannot subsequently be re-identified) with that of other customers and information received from other sources. We will do this to develop market insights, troubleshoot problems, detect and protect against error, fraud, and other criminal activity, identify behaviour/usage patterns and improve our Service generally. We may publish or share the insights we develop through this process.

Managing personal information

• Updating of personal information

Users are able to correct inaccurate personal information via the Service once they have successfully logged in. Alternatively, users may request AskLulo to correct inaccurate information via email at info@AskLulo.co.za. We will require that you verify you are in fact the owner of such personal information. Once the changes are made we will notify you by email at your nominated email address. If there is any personal information not accessible via the Service that you wish to have access to for purposes of correcting, contact dan@asklulo.com

• Deleting personal information

When a user closes their account we delete their Personal Information (including your Security Credentials for the Product/Service Provider websites and their account information). There may be some information that we are required by South African law to retain for the required amount of time.

• Opting-out to the disclosure of personal information

Users may opt out of the disclosure of their personal information. Should users choose to do this and should the opt-out be in respect of personal information necessary to provide the Service, AskLulo may not be able to extend certain features, and therefore rewards, to you and in such circumstances, we will notify you of this. Should you still wish to opt-out after such notification you will be entitled to do so or terminate your use of the Service, which will result in the deletion of your personal information?

Safety of minors

• Our services are not intended for and may not be used by minors.

Minors” are individuals under the age of 18. AskLulo does not knowingly collect personal data from Minors or allow them to register or consent to any service. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.

Change of ownership

• If AskLulo becomes involved in any merger, consolidation, or sale of our assets and this involves the sharing of user personal information:

AskLulo will ensure the confidentiality of such information and let you know before your personal information is transferred and becomes subject to a different Privacy Policy. Should you not wish for your personal information to be so transferred, you may terminate your use of the Service by closing your account, which will result in the deletion of your personal information

Modification of this privacy policy

• AskLulo may modify this privacy policy at any time, at AskLulo’s sole discretion, and such modification shall be effective immediately upon either posting of the modified privacy policy on the website or notifying users. Users will be fairly notified on the platform if there are any material changes to our policy, either wholly or in part. Users agree to review this privacy policy periodically to ensure that they are aware of any modifications. Users’ continued access or use of the website and/or the platform shall be deemed your conclusive acceptance of the modified privacy policy. If users do not cancel their subscription and continue to use the AskLulo services, they will be considered as having expressly consented to the modifications in the AskLulo privacy policy. If users disagree with the terms of this privacy policy or any updated privacy policy, they may close their AskLulo account at any time.

Information security policy[

We take the security of information very seriously.

• We ensure Bank-grade security out of the box

AskLulo adheres to the same procedures and standards used by banks, the military, and governments around the world

• Your information is always encrypted

256-bit encryption, certified by keeping your information indecipherable and private, always.

• How your account login details are kept safe.

The passwords and other authentication information you provide to us are passed, in an encrypted format. At no time can AskLulo or AskLulo staff access your credentials.

• How your information is kept secure while being transferred over the internet.

All information that is transferred over the Internet between your computer or device and our servers is encrypted using 256-bit encryption. We use an Extended Validation SSL certificate provided by DigiCert - a globally trusted digital certificate authority. This ensures that, even if intercepted, your information remains protected. In addition, all information transferred between our servers and those of our service providers is encrypted.

• How the physical servers that hold your information are secured.

All our servers are hosted in a secure Internet hosting facility operated by industry-leading hosting-provider Microsoft Azure. You can read more about Microsoft Azure information security policies here:https://docs.microsoft.com/en-us/azure/security/fundamentals/overview

• Who has access to the servers and other technology that holds your information?

Access to our servers, databases, and other infrastructure, as well as internal systems, is very tightly restricted. Only dedicated AskLulo team members who absolutely have to have access are able to do so. We regularly review each individual’s access rights and make necessary changes to ensure that we adhere to our ‘only the information you need’ policy.

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