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ZRK respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our websites (regardless of where you visit it from), or when you order or use our services, and tells you about your privacy rights and how the law protects you.
We will never (ever) sell your personal data to a third party.
This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.
PURPOSE OF THIS POLICY
This Policy aims to give you information on how ZRK collects and processes your personal data, including through your use of this website, and any data you may provide through this website, or when you contact us or sign up to our newsletters, commission or order a product or service, or take part in a survey.
This website is not intended for children under 16 and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
ZRK Limited is the controller and responsible for this website. and is the controller and responsible for your personal data (collectively referred to as ‘ZRK’, ‘we’, ‘us’ or ‘our’ in this Policy).
Our Technical Officer (CTO) is responsible for overseeing questions in relation to this Policy. If you have any questions, including any requests to exercise your legal rights, please contact the CTO using the details set out below.
Our full details are: ZRK Limited, with its registered office at Amelia House, Crescent Road, Worthing, West Sussex, England, BN11 1QR, UK.
CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in February 2019 and may be subject to further revisions.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you or any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel an order or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
(a) analytics providers such as Google based inside or outside the EU;
(b) advertising or social media networks, such as Google Ads, Facebook, Twitter, YouTube and Instagram based inside or outside the EU; and
(c) search information providers, such as Google, based inside or outside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing or third party direct marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us or by clicking ‘unsubscribe’ in any communication you receive from us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
To register you as a new customer or account holder
1.2 Type of data
1.3 Lawful basis for processing including basis of legitimate interest
Performance of a contract with you
To process and deliver a service or product order including:
(a) Manage payments, fees and charges
(b) Pass your details to a third party client or administrative or technology providers in order to perform our services (i.e. delivery or payment).
(c) Collect and recover money owed to us
(d) Perform services on behalf of a third party client of ZRK
2.2 Type of data
(e) Marketing and Communications
2.3 Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you or with a third party client of ZRK
(b) Necessary for our legitimate interests (for tax and legal liability purposes, or to recover debts due to us)
To manage our relationship with you which will include:
(b) If have some other form of contractual relationship with us
(c) Asking you to leave a review or take a survey
3.2 Type of data
(f) Marketing and Communications
3.3 Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated, to comply with our legal and tax obligations, or to study how customers use our products/services)
To enable you to take part in a prize draw, competition or complete a survey
4.2 Type of data
(e) Marketing and Communications
4.3 Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
5.2 Type of data
5.3 Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content, social media feeds and updates and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
6.2 Type of data
(e) Marketing and Communications
6.3 Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer and client relationships and experiences.
7.2 Type of data
7.3 Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers and clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
8.2 Type of data
8.3 Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
SURVEYS & PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data, and data related to previous purchases or interactions with us, to form a view on what we think may be of legitimate interest to you. This is how we decide which products, services and offers may be relevant for you.
We may send you product or service renewal reminders close to the anniversary of taking up a product or service or other communications we are obliged to send under a legal or contractual obligation.
You may receive marketing communications from us if you have expressly requested information from us about our services, or purchased goods or services, or made an enquiry, or if you provided us with your details when you entered a competition or registered for a promotion. We will not however send you generic marketing about ZRK unless you have expressly consented to receive it.
We will seek your express opt-in consent before we share your personal data with any company outside of the Company for marketing purposes. Or will ensure there is a lawful basis for us processing your personal data provided to us by a third party (for example, delivery of an order).
You can ask us or third parties to stop sending you marketing messages at any time or by following the opt-out or ‘unsubscribe’ links in any marketing message sent to you or by Contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service commission or order, warranty registration, product/service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In order to perform our services we may have to transfer your personal data outside the European Economic Area (‘EEA’).
Some of our external third party technology providers (as set out above) are based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers, clients, suppliers and employees (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, clients, suppliers or employees for tax and legal liability purpose, but we also keep this information to make it easier for customers and clients to make new, follow-on or repeat service orders. We will seek to renew consent for marketing communications on a periodic basis.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Consent means the unambiguous approval to use personal data in a specific way, it must involve a clear affirmative action (an opt-in). In relation to the use of Special Personal Data, the consent must be given expressly in relation to this use. We seek consent in relation to marketing permissions and in relation to our own employees or sub-contractors.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the ZRK group, where relevant, acting as joint controllers or processors and which provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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