Your privacy and permission is important to us Zingg Ltd (“We”) are committed to protecting and respecting your privacy.
Zingg Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). We are a limited company registered in England and Wales under company number 7455706 and have our registered office at 11 Berkeley Road, Westbury Park, Bristol, BS6 7PQ.
Our email address is firstname.lastname@example.org.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
2.What personal data we collect about you
From time to time we may collect the following data about you:
- Your name
- Your email address or addresses if you use more than one
- Your postal and billing address
- Your phone number or numbers if you use more than one
- Your business name
- Your website address or addresses if you use more than one
- Information about your business, for example what you do, your website address, your public-facing social media identities
- Any personal data that you choose to share with us in forms on our website, in feedback forms at events, over the phone, by email, by completing a survey, or in participation in things like polls in our online events.
- Data about how you use our website
- Technical data, such as your IP address, your login credentials, details about your browser, length of visit to pages on our website, page views, navigation paths, details about how often you visit our website, time zone settings and other technology on the devices you use to access our website
- Your contact preferences and topics of interest so that we can send you relevant information that you have stated a clear interest in receiving
- Photographs of you at events
- CV and application forms
- Billing information, such as your VAT number
- Sensitive Data: We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
3.How we may use your personal data
We will only use your personal data when legally permitted.
The most common uses of your personal data are:
- Where we need to perform the contract between us.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org or by using the link provided in any of the communications you receive from us.
We will typically use your data in the following ways:
- For Financial Management, for example:
- To process financial transactions so that you can purchase our products and services.
- To contact you about payment queries or outstanding debts.
- To pay you for goods and services we’ve bought from you.
- For Customer Services, for example:
- To provide you with the goods and services you have bought from us.
- To reply to any enquiries you make about our goods, services, press enquiries, job roles, etc.
- To assess your experience of using our products and services.
- To respond to any service issues or complaints
For Sales & Marketing, for example:
- To send you marketing communications where we are allowed by law to do so.
- To understand your business to see if our goods and services may be useful to you.
- To personalise your use of our website.
- To understand how you use or website so that we can continually improve it for visitors.
- To understand which of our products and services you may have been researching.
- To keep records of conversations we’ve had with you.
- To deliver relevant advertisements to you on platforms where you have your settings enabled to see re-targeted advertising.
For legal and Compliance Purposes, for example:
- To comply with any legal obligations that apply to our business or as required by a government authority, like HMRC.
- Bring legal claims against you in the unlikely event that you breach a contract or fail to make payment.
- For the ongoing health of our business, for example:
- To protect our business and website
- To manage and make decision about our business
- To obtain professional advice
4. Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. 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 email us at email@example.com 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.
We have four core categories, in which we have determined a lawful grounds to hold and process your data in order to contact you:
You are a customer: Where you have received coaching, registered a copy of your book, subscribed to one of our online courses, workshops, we hold and process your data for the purpose of fulfilling that contract, and for our legitimate interests of informing you of updates to those products or services.
You have actively requested specific information: Where you have requested one our useful downloads and the accompanying sequence of relevant emails, we hold and process your data to deliver the requested information to you, in essence fulfilling that contract.
You have actively added yourself to our marketing list: Where you have asked to be sent tips and updates from us by email by providing your email in a form that made it clear to you that this is what we would be holding and processing your data for.
You have asked us to get in touch after an event: Where we have met you at an event and you provided us with your business card or contact details on a sign-up form, we will only use this to contact you in follow-up to that event and to invite you to consent to marketing.
In terms of the different types of data we hold on you, we have determined the following lawful grounds to hold and process your data to help us run our business:
Communication Data: that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send to us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. The lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data: that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. The lawful ground for this processing is the performance of a contract between you and me and/or taking steps at your request to enter into such a contract.
User Data: that includes data about how you use our website together with any data that you post for publication on our website. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. The lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data: that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data: that includes data about your preferences in receiving marketing from me and our third parties and your communication preferences. WE process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. The lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
Advertising Data: We might use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising We serve you. The lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. The lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we compile statistics across all of our surveys to see trends, or We review your Usage Data to work out the percentage of website users using a specific feature of our site. If We link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Where We need to collect personal data by law, or under the terms of our contract and you don’t provide us with that data when requested, We might not be able to perform the contract (for example, to deliver our services to you). If you don’t provide us with the requested data, We might have to cancel our contract but if We do, We’ll notify you at the time.
We will only use your personal data for the purposes for which it was collected or a reasonably compatible purpose if necessary. In case We need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We might process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
5. Marketing communications
You will receive marketing communications from us if you have:
a) requested information from us or purchased goods or services from us; or
b) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
c) in each case, you have not opted out of receiving that marketing. We will get your active and express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org at any time or by using the link provided in the communications you have received.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 2 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
7. International Transfers
We are subject to the provisions of the General Data Protection Regulations (GDPR) that protect your personal data. Where we transfer your data to third parties
outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited
transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers, for example our website hosting, accountancy system and our customer database, are based outside the European
Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following
safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA
8. Data Security
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 such data.
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 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 (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 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.
10.Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- 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
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
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.
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.
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
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