© 2018 ZSL Capital Limited

ZSL Capital Limited. Registered Address - Brompton Place, 161 Brompton Road, London, United Kingdom, SW3 1QP. Registered Co. No. 11398339

ZSL Capital Limited (firm reference number: 814161) is an appointed representative of Zenzic Partners Limited which is authorised and regulated by the Financial Conduct Authority under firm reference number 646907.

Privacy Policy

This Privacy Policy advises you how we collect and process your personal data.

 

ZSL Capital Limited; a company incorporated in England and Wales with registered number 11398339 and its registered office situated at Brompton Place, 161 Brompton Road, London SW3 1QP.

 

Our contact email address is zsl@zenzicpartners.com

 

We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on:

•       the personal data we collect about you

•       what we do with your data, and

•       who your data might be shared with.

 

If you have a complaint with any aspect of how we collect and use your data, you have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you could contact us in the first instance if you have a complaint so that we can try to resolve it for you.

 

It is very important that the data that we hold about you is accurate and up to date. You can let us know of any changes to your personal data at any time by emailing us at the above email address.

 

WHO WE ARE

 

ZSL Capital Limited ('we' or 'us') are a 'data controller' and we are responsible for your personal data (referred to as “we”, “us” or “our” in this Privacy Policy). 

 

SENSITIVE DATA

 

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 Sensitive Data about you or any information about criminal convictions and offences.

 

PERSONAL INFORMATION PROVIDED BY YOU

 

We collect data about you through a variety of different methods including:

 

  • Direct interactions: You may provide data by filling in forms through our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

    • request our services;

    • send a message on our site;

    • subscribe to our service;

    • request resources or marketing be sent to you;

    • enter a competition, prize draw, promotion or survey; or

    • give us feedback;

    • give us your business card.
       

  • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for further details.
     

  • Third parties or publicly available sources: We may receive personal data about you from other third parties and public sources as set out below: 
     

    • Technical data from the following parties: 

    • Analytics providers such as Google based outside the EU;

    • Advertising networks such as Facebook based outside the EU; 

    • Search information providers such as Google based outside the EU;

    • Contact, financial and transaction data from providers of technical, payment and delivery services such as PayPal, based outside the EU;

    • Identity and contact data from publicly availably sources such as Companies House and the Electoral Register based inside the EU;

    • Email list providers such as Microsoft Outlook and Mailchimp based outside the EU;

    • Data on anti-spam protector based outside the UK; and

    • Accountancy details held by accountant, based in the UK. 

 

If you provide us with your contact details, we may contact you to request further information. If you do not want your personal data collected or used, please do not submit your data to us.

 

PERSONAL INFORMATION ABOUT OTHER INDIVIDUALS

 

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

•       give consent on his/her behalf to the processing of his/her personal data;

•       receive on his/her behalf any data protection notices;

•       give consent to the transfer of his/her personal data abroad; and

•       give consent to the processing of his/her personal data.

 

HOW WILL WE USE YOUR PERSONAL INFORMATION?

 

We will only use your personal data when we are legally permitted. The most common uses of your personal data are:

  • Where it is essential 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 agree and create the contract between us.

  • Where we need to comply with a legal or regulatory obligation.

 

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 remove your consent at any time by emailing us on the email address provided above.

 

PURPOSES FOR PROCESSING YOUR PERSONAL DATA

 

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 zsl@zenzicpartners.com if you would like further information about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out below.  The details below also describe the ways we intend to use your personal data, we have also explained what our legitimate interests are where relevant;

 

  • To register you as a new customer 

    • Data required: Identity, contact

    • Lawful basis for processing: Performance of a contract with you.

 

  • To process and deliver your order including:

 

(a) Manage payments, fees and charges

 

(b) Collect and recover money owed to us

  • Data required: Identity, contact, financial, transaction and marketing and communications

  • Lawful basis for processing: Performance of a contract with you; Necessary for our legitimate interests to recover debts owed to us.

 

  • To manage our relationship with you which will include:

 

(a) Notifying you about changes to our terms or privacy policy

 

(b) Asking you to leave a review or take a survey

  • Data required: Identity, contact, profile, marketing and communications

    • Lawful basis for processing: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.

 

  • To enable you to partake in a prize draw, competition or complete a survey

    • Data required: Identity, contact, profile, usage, marketing and communications

    • Lawful basis for processing: Performance of a contract with you; 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 our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • Data required: Identity, contact, technical

    • Lawful basis for processing: 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; Necessary to comply with a legal obligation.

 

  • To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

    • Data required: Identity, contact, profile, usage, marketing and communications, technical.

    • Lawful basis for processing:  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 relationships and experiences

    • Data required: Technical, usage.

    • Lawful basis for processing: Necessary for our legitimate interests to define types of customers for our products and services, to keep our site 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

    • Data required: Identity, contact, technical, usage, profile.

    • Lawful basis for processing: Necessary for our legitimate interests to develop our products/services and grow our business

       

 

MARKETING COMMUNICATIONS 

 

We will send you marketing communications if you have:

  1. requested information from us or purchased goods or services from us; or 

  2. if you provided us with your details and confirmed at the point of entry of your details that you agree that we can send you marketing communications; and

  3. in each individual case, you have not opted out of receiving that marketing. 

 

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

 

You can advise us or third parties to stop sending you marketing messages at any time by emailing us at zsl@zenzicpartners.com.  Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us because of a product/service purchase, warranty registration, product/service experience or other transactions.

 

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 the details in section 6 above:

  • Service providers who provide system administration services and IT.

  • Professional advisers including legal services, 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.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets. 

 

We require all third parties to whom we transfer your data to to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions and authorisation.

 

KEEPING YOUR DATA SECURE

 

We endeavour to protect the security of your personal data and 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. We use current industry standard technology to maintain the confidentiality and accuracy of the information you provide to us via the website. We also have security measures in place in our physical facilities to protect against loss, misuse or unauthorised alteration of the information which you provide to us.

 

As you may be aware, no data transmission over the internet can be entirely secure. As a result, while we will always use reasonable endeavours to protect your personal data, we cannot guarantee that any information you submit to us will be free from unauthorised third-party use or intrusion. Therefore, we cannot guarantee the security of your personal data nor the use of the website and accordingly we do not accept any responsibility for any damage or loss caused as a result.  However, we have put in place procedures to deal with any personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

We cannot guarantee that the website is free from viruses or malicious codes and accordingly we do not accept any responsibility for any damage or loss caused by any such viruses or codes. You agree that it is your responsibility to satisfy yourself that your own information technology / equipment used to access the website is protected against such viruses and / or codes

 

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.

 

TRANSFERS OF YOUR PERSONAL DATA OUT OF THE EEA

 

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 (set by European Law).

 

Many of our third parties service providers 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 a satisfactory level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use 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 suppliers 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 Europe and the US.

 

If none of the above protections are available, we may request your explicit consent to the specific transfer. You will have the right to decline this consent at any time.

 

Please email us at zsl@zenzicpartners.com if you want further information on the specific method used by us when transferring your personal data out of the EEA.

 

DATA RETENTION  

 

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, financial, or reporting requirements.

 

To define 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 certain circumstances you can ask us to remove your data from our systems: 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.

 

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 amendments and/or corrections of your personal data.

  • Request the removal of your personal data.

  • Oppose to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request the transfer of your personal data.

  • Right to withdraw your 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 zsl@zenzicpartners.com.  

 

 

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 unsubstantiated, 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 you’re your personal data is not disclosed to any unauthorised person. We may also contact you to ask you for further details 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 complicated or you have made several requests. In this case, we will notify you and keep you updated.

 

 

HOW TO CONTACT US

 

 

Please contact us if you have any questions about this privacy policy or the information we hold about you.

 

 

If you wish to contact us, please send an email to zsl@zenzicpartners.com or write to us at Brompton Place, 161 Brompton Road, London SW3 1QP or call us on 020 3818 9235.

 

 

CHANGES TO THE PRIVACY POLICY

 

 

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website.