Introduction to this policy
1 IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Zero One Services Limited]
Email address: [firstname.lastname@example.org]
Postal address: [Unit 30 Benyon Wharf, 295 Kingsland Road, London, United Kingdom, E8 4DQ
You have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2 THE DATA WE COLLECT ABOUT YOU
Personal data 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 and process different kinds of personal data about you which we have grouped together as follows:
- Identity & Contact Data includes first name, last name, username or similar identifier, title, gender, email address and telephone number.
- Technical & Usage Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. We also collect information about how you use our website.
- Marketing & Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect 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, we may not be able to perform the contract we have or are trying to enter into with you.
3 HOW WE COLLECT PERSONAL DATA REGARDING YOU?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity & Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data provided when you complete online forms.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our policy on cookies at Section 10 for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU;
- Contact Data from third parties who engage us to provide services to them.
- Identity & Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4 HOW WE USE PERSONAL DATA REGARDING YOU
We will only use personal data regarding you as allowed by law. Most commonly, we will use personal data regarding you in the following circumstances:
- To ascertain market demand for the goods/services featured on our site and to analyse and extrapolate from your responses the likely demand for various goods/services and the price which people might pay for them.
- Where you consent to receive such communications, to provide you with information about goods and services that may become available from us in the future.
- Where you consent to receive communications from third parties with information about goods and services that are similar to those that you have already enquired about, we will provide personal data regarding you to such third parties.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please read ‘Lawful Basis’ in the Glossary at Section 11 to find out more about the types of lawful bases that we will rely on to process personal data regarding you.
Generally, we do not rely on consent as a legal basis for processing personal data regarding you although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE PERSONAL DATA REGARDING YOU
The table below describes all the ways we plan to use personal data regarding you, 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 personal data regarding you 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 personal data regarding you where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity & Contact||Performance of a contract with you|
|To manage our relationship with you which will include:
(b) Asking you to take a survey
|(a) Identity & Contact
(b) Marketing & Communications
|Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|(a) Identity & Contact
(b) Technical & Usage
|(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 and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity & Contact
(b) Usage & Technical
(c) Marketing & Communications
|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 make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity & Contact
(d) Marketing & Communications
|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 personal data control mechanisms: such as an “unsubscribe” button in all emails sent to you to ensure that we do not send unsolicited emails.
PROMOTIONAL OFFERS FROM US
We may use your Identity & Contact Data and Technical & Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
We will get your express consent before we share personal data regarding you with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
CHANGE OF PURPOSE
We will only use personal data regarding you 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 personal data regarding you 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 personal data regarding you without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5 DISCLOSURES OF PERSONAL DATA REGARDING YOU
We may share personal data regarding you with the parties set out below for the purposes set out in the table Purposes for which we will use personal data regarding you above.
- Other companies that are members of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- External Third Parties as set out in the Glossary at Section 11.
We require all third parties to respect the security of personal data regarding you and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data regarding you for their own purposes and only permit them to process personal data regarding you for specified purposes and in accordance with our instructions.
6 INTERNATIONAL TRANSFERS
We share personal data regarding you within our corporate group. This may involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of personal data regarding you will involve a transfer of data outside the EEA.
Whenever we transfer personal data regarding you out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that the counterpart enters into specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
7 DATA SECURITY
We have put in place appropriate security measures to prevent personal data regarding you from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data regarding you to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data regarding you on our instructions and they are subject to a duty of confidentiality.
We have procedures in place 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.
8 DATA RETENTION: FOR HOW LONG WILL YOU USE PERSONAL DATA REGARDING ME?
We will only retain personal data regarding you for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data regarding you for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 personal data regarding you, the purposes for which we process personal data regarding you and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of personal data regarding you are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete personal data regarding you: see [your legal rights] below for further information.
In some circumstances we anonymise 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.
9 YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to personal data regarding you. Please read ‘Your Legal Rights’ in the Glossary at Section 11 to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. Some of these rights are not absolute and will be assessed when we receive a request.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access personal data regarding you (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 could 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 personal data regarding you (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 could 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.
All Cookies used by this website are used in accordance with current UK and EU Cookie Law.
Before the website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the website may not function fully or as intended.
This website may place the following Cookies:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality cookies||These are sued to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
|Targeting cookies||These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.|
You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete Cookies at any time; however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
UK and EU Cookie Law means the Privacy and Electronic Communications (EC Directive) Regulation 2003 as amended.
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 personal data regarding you for our legitimate interests. We do not use personal data regarding you 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 data regarding you 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 obligation means processing personal data regarding you where it is necessary for compliance with a legal obligation that we are subject to.
EXTERNAL THIRD PARTIES
- Service providers acting as processors based globally who provide IT and system administration services.
- Professional advisers acting as processors including consultants, lawyers, bankers, auditors and insurers based globally who provide consultancy, banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to personal data regarding you (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 personal data regarding you. 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 personal data regarding you 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 personal data regarding you 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 personal data regarding you 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 personal data regarding you 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 personal data regarding you. This enables you to ask us to suspend the processing of personal data regarding you in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of data regarding you but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of personal data regarding you to you or to a third party. We will provide to you, or a third party you have chosen, personal data regarding you 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 personal data regarding you. 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.