Zeeon - Privacy Policy

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Welcome to the ZEEON privacy policy.

We at ZEEON take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (“UK GDPR”). We are also subject to the EU General Data Protection Regulation (“EU GDPR”) in relation to services we offer to individuals and our wider operations in the European Economic Area (“EEA”).

1) Key terms

It would be helpful to start by explaining some key terms used in this policy:

2) Personal data we collect about you

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:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details, details of your subscription package and any direct debits you have set up with us.
• Transaction Data includes details about payments to and from you, other details of products and services you have purchased through the Platform, and details of your subscription package.
• Technical Data includes internet protocol (IP) address, your login data, 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 our website or Platform.
• Profile Data includes your username and password, preferences, including any other personal information that may be uploaded to the Platform as a part of the Services, feedback and survey responses.
• Usage Data includes information about how you use our website, Platform and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Correspondence Data includes information contained in or relating to any communication that you send to us, including the communication content and metadata associated with the communication. This includes any personal data contained in any correspondence as part of a response to a survey you may undertake.
• Content Data includes information, data, media and content that you upload or link to the Platform. This information may not include your personal data, however if any of the data directly or indirectly identifies you, we will process the personal data in accordance with this privacy policy.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our Platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

We collect and use this personal data to provide the Platform and the Services to you. 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. In this case, we may have to cancel any services you have with us but we will notify you if this is the case at the time.

3) How your personal data is collected

WE USE DIFFERENT METHODS TO COLLECT DATA FROM AND ABOUT YOU INCLUDING THROUGH:

DIRECT INTERACTIONS.

YOU MAY GIVE US YOUR IDENTITY, CONTACT AND FINANCIAL DATA BY FILLING IN FORMS ON OUR WEBSITE AND/OR PLATFORM OR BY CORRESPONDING WITH US BY POST, PHONE, EMAIL OR OTHERWISE. THIS INCLUDES PERSONAL DATA YOU PROVIDE WHEN YOU:

• SUBSCRIBE TO OUR SERVICES AND PLATFORM;
• CREATE AN ACCOUNT ON OUR WEBSITE;
• USE OUR SERVICES OR ANY OTHER SERVICE THAT WE PROVIDE OR OUR PUBLICATIONS;
• REQUEST MARKETING TO BE SENT TO YOU;
• ENTER A COMPETITION, PROMOTION OR SURVEY;
• UPLOAD INFORMATION TO OUR PLATFORM OR ENGAGE IN THE SERVICES; OR
• GIVE US FEEDBACK OR CONTACT US.

AUTOMATED TECHNOLOGIES OR INTERACTIONS.

AS YOU INTERACT WITH OUR WEBSITE, WE WILL AUTOMATICALLY COLLECT TECHNICAL DATA ABOUT YOUR EQUIPMENT, BROWSING ACTIONS, VIEWING HABITS AND INTERACTIONS AND PATTERNS. WE COLLECT THIS PERSONAL DATA BY USING COOKIES, SERVER LOGS AND OTHER SIMILAR TECHNOLOGIES. WE MAY ALSO RECEIVE TECHNICAL DATA ABOUT YOU IF YOU VISIT OTHER WEBSITES EMPLOYING OUR COOKIES. PLEASE SEE OUR COOKIE POLICY 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 THE FOLLOWING PARTIES:
• ANALYTICS PROVIDERS SUCH AS GOOGLE BASED OUTSIDE THE UK;
• ADVERTISING NETWORKS; AND
• SEARCH INFORMATION PROVIDERS.
• CONTACT, FINANCIAL AND TRANSACTION DATA FROM PROVIDERS OF TECHNICAL, PAYMENT AND DELIVERY SERVICES SUCH AS STRIPE.
• IDENTITY AND CONTACT DATA FROM PUBLICLY AVAILABLE SOURCES SUCH AS COMPANIES HOUSE AND THE ELECTORAL REGISTER BASED INSIDE THE UK.
• IDENTITY DATA, CONTACT DATA AND EXTRACTED DATA FROM THIRD PARTY WEBSITES MADE AVAILABLE TO THE PUBLIC.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason. These reasons are:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

Generally, we do not rely on consent as a legal basis for processing your personal data 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.

The table below explains what we use your personal data for and why.

Although we do not process special category personal data, in the event that we did, we will also ensure we are permitted to do so under data protection laws, eg:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

We may use your Identity, Contact, Technical, Usage and Profile 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 or use our services and you have not opted out of receiving that marketing.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘ How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

• contacting us at any time by email at [email protected]
• following the opt-out links on any marketing message sent to you; or
• by logging into your profile and checking or unchecking relevant boxes to adjust your marketing preferences.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy

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.

Who we share your personal data with

We may share your personal data with the parties set out below for the purposes set out in the table HOW AND WHY WE USE YOUR PERSONAL DATA above.

• External Third Parties as set out in the Key Terms
• Third Parties to whom we are required to provide Personal Data in order to provide you with the Platform, content and the Services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We may also need to:

• share personal data with external auditors, eg in relation to ISO or Investors in People accreditation and the audit of our accounts;
• disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
• share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

8) Where your personal data is held

Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.

9) How long your personal data will be kept

We will only retain your personal data 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 your personal data 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 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, regulatory, tax, accounting or other requirements.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we will 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.

10) Transferring your personal data out of the UK and EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:

• with your and our service providers located outside the UK/EEA;
• if you are based outside the UK/EEA;
• where there is a European and/or international dimension to the services we are providing to you.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:

• the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law

These are explained below.

11) Adequacy decision

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:

• all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
• Gibraltar; and
• Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.

12) Transfers with appropriate safeguards

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.

The safeguards will usually include using legally-approved standard data protection contract clauses or model contract clauses.

To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact us (see ‘How to contact us’ below).

13) Transfers under an exception

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

14) Further information

If you would like further information about data transferred outside the UK/EEA, please contact our Data Protection Officer (see ‘How to contact us’ below).

15) Your rights

You have the following rights, which you can exercise free of charge:

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

• complete a data subject request form—available on request; or
• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (eg your full name, address and username) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.

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 could refuse to comply with your request in these circumstances.

16) Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

17) How to complain

contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have./p>

You also have the right to lodge a complaint with the Information Commissioner [or any relevant European data protection supervisory authority]. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

18) Changes to this privacy policy

We keep our privacy policy under regular review. This version was last updated on [DATE].

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.

We may change this privacy notice from time to time—when we do we will inform you via our website.

19) How to contact us

You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below: