Privacy Policy

1.    What information does ZHULIAN Nutrition collect?

ZHULIAN limits the collection of personal information to what is relevant to the purposes of collection whether directly or through third parties acting our behalf, and we always collect personal information using lawful and fair means, consistent with the jurisdiction governing the collection of personal information.

Information You Provide Us Directly

At different occasions, you may provide information directly to ZHULIAN, such as your first and last name, mailing address, telephone number, email address, credit card information, banking information, and biographical information (including, but not limited to, date of birth, and marital status). For example, you may provide us with information when using the sites or when becoming an ZBO (“Zhulian Business Owner”). If you do not provide us with the requested information, in some cases, we will not be able to provide you the service you have requested.

If you disclose to us any information of another individual, you are required to have secured the appropriate consent of that individual for disclosing such information to us.

Information About Your Device and Your Use of the Sites

We may gather certain information automatically, such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamps, your Site activity (including the Site content you view, mouse movements, mouse clicks, taps, swipes, and information you view), and/or clickstream data for purposes such as analyzing trends, administering the Sites, improving the function and content of the Sites, and enforcing our Terms. We use standard Internet technologies, such as cookies, web beacons, session replay/screen capture, and similar technologies to collect this information, as explained below in the section on cookies.

We may also collect precise information about your location, such as your mobile device’s GPS coordinates, cell tower information and/or WiFi signals. ZHULIAN may use this information to personalize your experience in connection with your use of the Sites, or other ZHULIAN products and services. If you do not want ZHULIAN to collect and use your specific geolocation information, you can disable the location features on your device. Check your device manufacturer settings for how to do so.

Information from Third Party Sources

We may receive additional information about you from public and commercially-available sources and other third parties. ZBO may also share information about you with ZHULIAN. If you access third-party services, such as Facebook, Instagram, Google, or Twitter through the Sites, to login to the Sites or to share information about your experience on the Sites with others, we may collect information from these third-party services. We may combine all of the information we collect and receive about you, both online and offline, and use or disclose it in the manner described in this Privacy Policy.

We may also receive the following types of personal information about you from our ZBOs, depending on what you choose to provide to them: name, contact information, payment information, and wellness information (including but not limited to height, weight, BMI).

2.    How does ZHULIAN use my Information?

We use the information we collect about you for a variety of purposes, including: providing you with the products, services and support you request; processing your transactions and shipping your orders; communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; to better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; improving our products, services and operations; and ensuring compliance with our company policies and rules and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others. We also use this information to validate sales made by ZBOs, to help ZBOs search for, communicate with and validate customers in our systems, and for ZHULIAN compliance purposes. ZHULIAN or its authorized third parties may contact you directly for these purposes using various contact methods described below.

ZHULIAN may also use this information to support the operation of the ZBOships, and to maintain proper functioning of the ZHULIAN Azana Golden Business Plan. For example, information about ZBO may be used to support, calculate and track your product discount and to provide you with information on special promotions. Information about ZHULIAN ZBOs may be used to support, calculate and track discounts, earnings and bonuses, to issue payments to and report income to taxing authorities, to provide training, and to ensure compliance with applicable law and company policies, plans and agreements, including the ZBOship Application and Agreement. We may retain your information for as long as needed to: provide you services; fulfill other legitimate business needs, such as maintaining the proper function of the Marketing Plan; fulfill our compliance and legal obligations; and resolve disputes and enforce our agreements, including the ZBOship Agreements.

3.    With Whom does ZHULIAN Share my Information?

Affiliates and Partners

We may share any of the personal information described above in Section 1 with our affiliates (companies that control, are controlled by, or are under common control with, ZHULIAN) as well as select partners. Examples of how these entities may use your information include making predictions about your interests and providing you with special offers, promotions, advertisements, and other materials.

Vendors & Service Providers

We may share any of the personal information described above in Section 1 with vendors and service providers that perform functions on our behalf. Examples of such functions include fulfilling orders, delivering packages, email administrative functions, processing credit card payments, providing customer service, and for market research. Vendors and service providers must handle your personal information in accordance with ZHULIAN instructions and are prohibited from using or disclosing your personal information for any other purpose.

ZBOs

If you are an ZBO or Customer, we may share your information with other ZBOs, including without limitation as part of a Report which contains information (such as name, contact information, level or rank, and volume and sales statistics) on ZBO’s downline. (The downline consists of all ZBOs that were personally sponsored by a particular ZBO, and in turn, all other persons sponsored by the subsequent ZBOs.)

To the extent the Report contains data from persons outside of the Singapore, we have taken appropriate measures to protect the data in accordance with applicable law. Lineage Reports are provided to ZBOs in strict confidence and for the sole purpose of supporting the ZBOs in further developing their ZHULIAN businesses, including for use in marketing tools and platforms.

We may share your information with ZBOs to offer and provide you with products and services, and these ZBOs may further share your information as described in their privacy policies. We may also share your information with ZBOs so that they can provide you with a more personalized experience, such as recommending products and services that are most relevant to you. ZBOs who receive your information are bound by the terms of their ZBO Agreement and the privacy and data protection covenants contained therein. Some of these ZBOs may be based in countries that do not offer the same or a similar level of privacy protection as is available in your own country.

Legal & Compliance Disclosures

We may also disclose your information: as required by law, such as to comply with a subpoena, legal proceedings, or similar legal process, including disclosure to authorized third party auditors; or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate or prevent fraud, or respond to a government request.

Other Parties with Your Consent

In addition to the sharing described in this Privacy Policy, we may also share information about you with third parties for any other purpose disclosed to you at the time we collect the information or pursuant to your consent or direction.

4.    How will ZHULIAN Communicate with me?

ZHULIAN may communicate with you via email, postal mail, telephone, text message, or other means on a regular basis to provide requested products and services and/or in regards to issues relating to your ZHULIAN business (if you are a ZBO).

5.    Is my Personal Information Secure?

We take reasonable steps to ensure that the personal information we collect about you remains accurate, timely and secure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and while we strive to protect your personal information, we cannot guarantee or warrant its complete security.

6.    How can I Access or Correct my Information?

ZHULIAN respects your control over your information. In some instances, you may visit our Sites to verify and update certain information. Upon request, we will confirm whether we hold or are processing information that we have collected from you. You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. Our typical response time for requests is 30 days. In order to make personal information requests, please contact us online or offline, using the information provided below.

7.    Online Advertising.

We may display advertising on our website and partner with third parties to manage advertising on other websites for our products and services. We may also partner with third parties, including business partners, advertising networks, and other advertising service providers, who gather information about you on our Sites and other sites to provide you with advertisements on the Sites and elsewhere online based on your browsing history and tailored to your interests, preferences, and characteristics. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Policy.

Some third parties collect information about users of our Sites to provide interest-based advertising on our Sites and elsewhere, including across browsers and devices. These third parties may use the information they collect on our Sites to make predictions about your interests in order to provide you ads (from us and other companies) across the Internet. Some of these third parties may participate in industry-developed programs designed to provide consumers with choices about whether to receive targeted advertising. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable targeted ad technologies in mobile apps. Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.

8.    Modifications to this Policy.

This Privacy Policy was last updated on the date listed at the beginning of this Policy. ZHULIAN reserves the right to change this Privacy Policy at any time. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. Your subsequent use of the Sites will be deemed acceptance of such changes. Be sure to review this Privacy Policy periodically to ensure familiarity with its most current version. By using the Sites following the posting of changes to this Privacy Policy, you agree to all such changes.

9.    What if I have Questions?

ZHULIAN takes privacy concerns seriously. If you have questions or comments, you may contact us at [email protected].

Supplemental Privacy Policy of ZHULIAN (Singapore), Pte. Ltd.

For the purposes only of the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”), you consent to the collection, use, disclosure and processing of your personal information for the purposes and in the manner set out in this Policy, insofar as such collection, use, disclosure and/or processing occurs in Singapore.