ZOOC LTD

Privacy and Cookies Policy

1. Introduction

1. We are committed to safeguarding the privacy of our website visitors and service users.
   
   
2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
   
   
3. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
   
   
4. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. 
   
   
5. In this policy, “we”, “us” and “our” refer to ZOOC LTD. For more information about us, see Section 18.

2. How we use your personal data

1. In this Section 2 we have set out:
   (a) the general categories of personal data that we may process;
   (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   (c) the purposes for which we may process personal data; and
   (d) the legal bases of the processing.
   
   
2. We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics and our server logs. This usage data may be processed for the purposes of analysing the use of the website and services, and ensuring the security of our website and services. The legal basis for this processing is our legitimate interests, namely monitoring, improvement and the security of our website and services.
   
   
3. We may process information included in you account on our website (“account data“). The account data may include your company name, first name, last name, email address, phone number, address, security question and answer, and password. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, record-keeping, maintaining backups and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   
   
4. We may process your information included in your personal profile on our website (“profile data“). The profile data may include your company name, client group, account status, preferred payment method, language and currency. The source of the profile data is you. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, record-keeping, and personalising our website and services to you. The source of the account data is you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
   
   
5. We may process your information that is provided to us in the course of the use of our services, or that we obtain through providing you with IT support services (“service data“). The service data may include, but is not limited to, usernames and passwords, domain names, service URLs, user information, as well as specifications and information about your networks, Internet connections, servers, laptops, computers, tablets, mobile devices, printers, applications, backups, antivirus and malware protection, security, routers and firewalls, spam and content filtering. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, record-keeping, maintaining backups and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   
   
6. We may process information that you post for publication on our website or through our services (“publication data“). The source of the publication data is you. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business.
   
   
7. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may include your contact details, the enquiry content and metadata associated with the enquiry. The source of the enquiry data is you, our website will also generate metadata associated with enquiry when using the website contact forms. The enquiry data may be processed for the purposes of communicating with you, record-keeping, and offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
   
   
8. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details, your bank account details, and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The source of transaction data is you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
   
   
9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The source of notification data is you. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   
   
10. We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The source of correspondence data is you. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
    
    
11. We may process personal information stored on your IT systems (“customer data“). This customer data may include personal data about you, your employees, your suppliers, your own website and service users, and other natural persons. The source of customer data is you. The customer data may be processed for the purposes of providing our services, ensuring the security of our services, and maintaining backups. The legal basis for this processing is consent and our legitimate interests, namely the performance of a contract between you and us.
    
    
12. We may process information you upload to our servers, information submitted through and stored by your website, and information sent by email from you or to you (“hosted data“). This hosted data may include personal data about you, your employees, your suppliers, your own website and service users, and other natural persons. The source of hosted data is you. The hosted data may be processed for the purposes of providing our services, ensuring the security of our services, and maintaining backups. The legal basis for this processing is consent and our legitimate interests, namely the performance of a contract between you and us.
    
    
13. All calls to and from us are recorded. We may process information contained in or relating to any telephone conversations (“call data“). This call data may include personal data about you, your employees, your suppliers, your own website and service users, and other natural persons. The source of call data is you. The call data may be processed for the purposes of providing our services, ensuring the quality of our services, dealing with complaints and queries, and maintaining backups. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our business, record-keeping, improving our services, training, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
    
    
14. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    
    
15. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    
    
16. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    
    
17. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal information to others

1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
   
   
2. We may disclose your account data, profile data, and service data to our suppliers or subcontractors insofar as reasonably necessary for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. 
   
   
3. We may disclose your enquiry data to our suppliers or subcontractors for the purpose of obtaining professional advice, pricing and other relevant details to enable us to respond to your enquiry. 
   
   
4. Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 
   
   
5. Incoming telephone calls may be handled by our call handling service provider. We will share call data with our call handling service provider only to the extent necessary for the purposes of logging information from you during busy times or out-of-hours. Call data may also include additional categories of personal information that you disclose to us during the call. 
   
   
6. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
   
   
2. We do not have offices outside the European Economic Area (EEA).
   
   
3. The hosting facilities for our websites are situated in the United Kingdom.
   
   
4. We use the services of third-parties located outside the European Economic Area (EEA).
   
   
5. Amazon Web Services, Inc. (AWS) is situated in the United States of America. Amazon provide one of our storage locations for backups of customer data, however we use a location based in EU (London). Transfers to AWS will be protected by appropriate safeguards, namely Privacy Shield Certification, the use of Standard Contractual Clauses, ISO 27001 certification, ISO 27017 certification, and ISO 27018 certification.
   
   
6. Google is situated in the United States of America. Google provide storage locations for files, backups and email services. Transfers to Google will be protected by appropriate safeguards, namely Privacy Shield Certification, the use of Standard Contractual Clauses, ISO 27001 certification, ISO 27017 certification, and ISO 27018 certification.
   
   
7. Microsoft is situated in the United States of America. Microsoft provide storage locations for files, backups and email services. Transfers to Microsoft will be protected by appropriate safeguards, namely Privacy Shield Certification, the use of Standard Contractual Clauses, ISO 27001 certification, ISO 27017 certification, and ISO 27018 certification.
   
   
8. A copy of the Standard Contractual Clauses approved by the European Commission can be obtained from: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
   
   
9. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
   
   
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   
   
3. We will retain your personal data as follows:
   (a) Account data will be retained while there is an active contract in place and for a minimum of 6 years and maximum period of 10 years after the date of the termination of the last contract.
   (b) Profile data will be retained while there is an active contract and for a minimum of 6 years and a maximum period of 10 years after the date of the termination of the last contract.
   (c) Enquiry data will be retained for a minimum period of 6 years and a maximum period of 10 years after the date of the enquiry.
   (d) Transaction data will be retained for a minimum period of 6 years and a maximum period of 10 years after the date of the transaction.
   (e) Correspondence data will be retained for a minimum period of 6 years and maximum period of 10 years after the date of the correspondence.
   (f) Call data will be retained for a minimum period of 6 year following the date of the call, and for a maximum period of 10 years following the date all services with ZOOC LTD are cancelled or terminated and your account is closed.
   
   
4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
   (a) the period of retention of Usage data will be for a minimum period determined by the storage space available for this data, and a maximum of 10 years.
   (b) the period of retention of Service data will be while there is an active contract and for a maximum period of 10 years after the date of the termination of the contract.
   (c) the period of retention of Publication data will be determined based on the outcome of an audit when reviewing our online content, normally when redeveloping our websites from time to time.
   (d) the period of retention of Notification data will be a maximum of 10 years after you unsubscribe from all notifications.
   (e) the period of retention of Customer data will be as specified in the backup policy and only while the backup service contract is active. Customer data is only retained where we provide you with a backup service contract.
   (f) the period of retention of Hosted data will be while there is an active hosting contract and for a maximum period of 90 days. Where a hosting backup service contract is also active, the backups of the hosting data will be retained for a maximum period of 3 months.
   
   
5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of personal data

1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
   
   
2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
   
   
3. The following personal data will be stored by us in encrypted form: password(s).
   
   
4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
   
   
5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
   
   
6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

7. Amendments

1. We may update this policy from time to time by publishing a new version on our website.
   
   
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
   
   
3. We may notify you of changes to this policy by email.

8. Your rights

1. In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
   
   
2. Your principal rights under data protection law are:
   (a) the right to access;
   (b) the right to rectification;
   (c) the right to erasure;
   (d) the right to restrict processing;
   (e) the right to object to processing;
   (f) the right to data portability;
   (g) the right to complain to a supervisory authority; and
   (h) the right to withdraw consent.
   
   
3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 
   
   
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   
   
5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
   
   
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   
   
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
   
   
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   
   
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   
   
10. To the extent that the legal basis for our processing of your personal data is:
    (a) consent; or
    (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
    
    
11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    
    
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    
    
13. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

9. Third party websites

1. Our website includes hyperlinks to, and details of, third party websites.
   
   
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

1. Our website and services are targeted at persons over the age of 18.
   
   
2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Acting as a data processor

1. In respect of customer data and hosted data, we do not act as a data controller; instead, we act as a data processor.
   
   
2. Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13. About cookies

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   
   
2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
   
   
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14. Cookies that we use

1. We use cookies for the following purposes:
   (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website
   (b) status – we use cookies to help us to determine if you are logged into our website.
   (d) personalisation – we use cookies to store information about your preferences and to personalise our website for you.
   (e) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
   (g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

15. Cookies used by our service providers

1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
   
   
2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. 

16. Managing Cookies

1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
   (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
   (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
   (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
   (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
   (e) https://support.apple.com/en-gb/guide/safari/sfri11471/mac (Safari); and
   (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
   
   
2. Blocking all cookies will have a negative impact upon the usability of many websites.
   
   
3. If you block cookies, you will not be able to use all the features on our website.

17. Our details

1. This website is owned and operated by ZOOC LTD.
   
   
2. We are registered in England and Wales under registration number 13501820, and our registered office is at 22 Kingskerswell Road, Newton Abbot, TQ12 1DG.
   
   
3. Our principal place of business is at 22 Kingskerswell Road, Newton Abbot, TQ12 1DG.
   
   
4. You can contact us:
   (a) by post, to the postal address given above;
   (b) using our website contact form;
   (c) by telephone on 01626 785 910; or
   (d) by email using privacy@zooc.co.uk