Privacy Policy

1. Introduction

Zulu Limited ("Zulu", "we", "us" or "our") is a company incorporated in Papua New Guinea, with its registered office at 13th Street, Top Town, Lae, Morobe Province, Papua New Guinea. We respect your privacy and are committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect, how we use and protect it, who we share it with, and the rights and choices available to you when you visit our website, request a quotation, or otherwise engage our procurement and supply services.

This Policy is framed in accordance with the constitutional right to privacy recognised under Section 49 of the Constitution of the Independent State of Papua New Guinea, the obligations applicable to electronic dealings under the Cybercrime Code Act 2016, and the National Information and Communications Technology Act 2009. Where we deal with international clients, donors or partners, we also seek to align our practices with widely recognised data-protection standards, including the principles of the European Union General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and the Australian Privacy Act 1988 (Cth), to the extent those frameworks apply to a particular engagement.

2. Information We Collect

We collect personal information that is necessary to respond to your enquiries, prepare quotations, fulfil orders, and meet our legal and contractual obligations. The categories of information we may collect include:

Information you provide to us

This includes your name, job title, employer or organisation, postal and delivery address, email address and telephone number; the details of goods or services you request; purchase order, tender and contract references; and any other information you choose to provide when corresponding with us. Where you transact with us, we may also collect billing details and taxpayer information such as your IRC Taxpayer Identification Number (TIN) required to issue Goods and Services Tax (GST) compliant invoices under the Goods and Services Tax Act 2003.

Information collected automatically

When you visit our website, we may automatically collect limited technical data such as your IP address, browser type, device information, pages viewed and the date and time of your visit. This information is collected through cookies and similar technologies and is used to operate the site securely and to understand how it is used. You can control or disable cookies through your browser settings; some features of the site may not function correctly if cookies are disabled.

Information from third parties

In the course of sourcing and supply we may receive information about you from suppliers, freight and logistics providers, banks, credit reference checks, and publicly available registers such as those maintained by the Investment Promotion Authority. We only collect such information where it is relevant to a legitimate business purpose.

3. How We Use Your Information

We use your personal information only for legitimate business purposes connected with our procurement and supply services.

These purposes include: responding to enquiries and preparing quotations; sourcing, purchasing, importing and delivering goods on your behalf; administering contracts, purchase orders and tenders; issuing GST-compliant tax invoices and maintaining the records required for audit and acquittal; managing payments and our supplier relationships; meeting our obligations under Papua New Guinea law, including taxation, customs and company-law requirements; preventing fraud and securing our systems; and, where you have consented, sending you service updates or information about our offerings. We do not sell your personal information, and we do not use it for automated decision-making that produces legal effects concerning you.

4. Disclosure of Information

We disclose personal information only where it is necessary and lawful to do so.

We may share information with: suppliers, manufacturers, freight forwarders and logistics partners engaged to fulfil your order; professional advisers such as accountants, auditors and lawyers; banks and payment processors; and government authorities where disclosure is required by law, including the Internal Revenue Commission, the PNG Customs Service, and the National Procurement Commission in connection with public-sector tenders governed by the National Procurement Act 2018. We may also disclose information where required to comply with a court order, a lawful request from a regulator, or to protect our rights, property or safety. Where we engage third parties to process information on our behalf, we require them to handle it securely and only for the purposes we specify.

5. Data Security and Storage

We take reasonable technical and organisational measures to protect your personal information against loss, misuse, unauthorised access, disclosure or alteration. These measures include access controls, secure storage of records, and limiting access to information to those staff and partners who need it. Unauthorised access to, or interference with, our electronic records is an offence under the Cybercrime Code Act 2016, and we treat the integrity of your data accordingly. While we strive to protect your information, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention

We keep personal information only for as long as it is needed for the purposes described in this Policy, or for as long as we are required to retain it by law. In particular, accounting and tax records are retained for a minimum of seven years in line with the record-keeping obligations under the Income Tax Act 1959 and the Goods and Services Tax Act 2003. When information is no longer required, we take reasonable steps to delete or securely destroy it.

7. Your Rights and Choices

You have the right to ask us what personal information we hold about you, to request that we correct information that is inaccurate or out of date, and to ask that we delete information where we are not legally required to keep it. You may also withdraw your consent to marketing communications at any time by contacting us or using the unsubscribe option in our emails. Where the GDPR or another data-protection law applies to your dealings with us, you may have additional rights, including rights to data portability, to restrict or object to certain processing, and to lodge a complaint with a supervisory authority. We will respond to genuine requests within a reasonable time and free of charge, except where the law permits a fee.

8. Cookies

Our website uses cookies and similar technologies to make the site work, to remember your preferences, and to understand how visitors use the site so we can improve it. You can set your browser to refuse some or all cookies, or to alert you when a site sets a cookie. If you disable cookies, some parts of the site may not work as intended.

9. International Transfers

Because we source goods internationally and work with overseas suppliers, donors and logistics providers, your information may be transferred to and processed in countries outside Papua New Guinea. Where this occurs, we take reasonable steps to ensure that your information continues to be protected to a standard consistent with this Policy and with applicable law.

10. Children's Privacy

Our website and services are directed to businesses, government bodies and organisations, and are not intended for children. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to remove it.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in the law. The current version will always be available on this page, and the "last updated" date below indicates when it was most recently revised. We encourage you to review this page periodically.

12. How to Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any of your rights, please contact us:

Zulu Limited — 13th Street, Top Town, Lae, Morobe Province, Papua New Guinea. Telephone: +675 8148 0186. Or reach us through the contact form on our website.

Last updated: 15 June 2026