Privacy Policy

NOTICE ON THE FAIR PROCESSING OF PERSONAL DATA

Last updated: 13 February 2019

  1. INTRODUCTION

This website is owned and operated by Zenb US Inc ("Zenb"), a limited company incorporated under the laws of Delaware, USA. Our registered office is at 1661 Feehanville Road, Suite 300, Mt Prospect, IL  60056, USA.

This Notice is to inform consumers (i.e. “you”) of how we at Zenb (“us”) process your personal data and the measures and processes we have put in place to ensure its adequate protection.

We provide you with this information as required by the General Data Protection Regulation 2016/679 ("GDPR").

  1. LAWFUL PROCESSING

We will only process your personal data:

(a) where you have given your consent;
(b) where the processing is necessary to provide our products or services to you;
(c) where the processing is necessary to respond to a request from you;
(d) where the processing is necessary to maintain our relationship with you;
(e) where the processing is necessary for compliance with our legal and regulatory obligations;
(f) where the processing is necessary in order to protect your vital interest.

 

In case of (a) above, you may withdraw your consent at any time, by making a request as set out below.

  1. WHAT PERSONAL DATA WE COLLECT ABOUT YOU
3.1 We process the following types of personal data about you:
(a) Your name, email address, twitter and/or Instagram handle and other contact details;
    (b) Details of your preferences for types of marketing events or materials;
      (c) Your messages, feedback or contributions to customer surveys and questionnaires;
        (d) Other communications you send to us; and
          (e) Details of your access to our websites (including IP address).
          3.2 It may be mandatory for you to provide us with your personal data, to enable us to manage our business and operations, to maintain our relationship with you, to provide our products or services to you or to comply with our legal and regulatory obligations. If you fail to provide your personal data when requested, we may not be able to maintain our relationship with you or to provide our products or services to you.
          3.3 We make every effort to maintain the accuracy and completeness of your personal data which we store and to ensure all your personal data is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you (see section 10 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
          4. HOW WE COLLECT PERSONAL DATA
            We usually collect your personal data from the information you submit during the course of your relationship with us. This will typically be through;
              • You sending us emails and other correspondence
              • The forms and documents used when you sign up to our marketing or market data news lists
              • The sign-up information you use to access any of our products or services
              • The information you as a customer provide to us as supplier so we can ship to you and bill you and can contact you on orders and/or issues
              1. HOW WE USE PERSONAL DATA
              We will process your personal data for the following purposes:
              (a)  to provide you with requested products or services;
              (b)  to respond to your messages or posts to us;
              (c)  to provide you with promotional and marketing materials about our products and services that we think you may be interested in;
              (d) to manage, develop and improve our product range, services, stores, information technology systems and websites;
              (e) for monitoring and assessing compliance with various laws and our policies and standards;
              (f) to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
              (g)  to carry out money laundering, financial and credit checks and for fraud and crime prevention and detection purposes;
              (h) for administrative purposes in relation to the security and access of our websites and applications;
              (i) to comply with court orders and exercise and/or defend our legal rights;
              (j) to deal with your complaint or any concerns about your health and/or wellbeing;
              (k)  for any other legitimate business purpose; and
              (l) as otherwise permitted or required by any applicable law or regulation

              In some case, such as for instance a competition or prize draw, you may provide us with specific information, such as a photo, which could contain personal data.  In those specific cases we will always tell you for what objective we gather the information and for how long we intend to keep it.


              Please note; “PROPERTIES OF A COMPUTER FILE”; Each picture file that you submit to us may contain additional information in its “PROPERTIES”.  Pictures taken with a mobile phone may indicate in its “PROPERTIES” the GPS coordinates of the location were the picture was taken.  As a matter of caution, we recommend that you to remove all additional data in “PROPERTIES” before submitting a picture to us.

              Where you wish to share personal data on specific matters like health, with us, to enable us to handle a question and/or complaint we may ask you for your consent before we process such data.  If you submit your request online we may ask for your consent online before you can submit your question.  If you submit your correspondence by postal mail we may first have to contact you and ask you for your written consent.  If you call us we may ask you for your consent in the telephone call and will record you answer before we can process your personal data. In all three incidences we would maintain a record of your consent for us to process such specific data.
              1. COOKIES
              On our websites we use two different categories of cookies; strictly necessary cookies and performance cookies.  The first category of cookies is used to store a unique identifier which allows us to manage and to uniquely identify you as a user so we can provide you with a consistent and accurate service. The second category of cookies collects information about your use of our website and may be used by us to provide you with more similar information. For more information about how we use cookies, please read our cookie policy; https://zenb.co.uk/pages/cookie-policy
              1. INTERNATIONAL TRANSFERS OF PERSONAL DATA 
              This website is controlled and operated from the United States and the files containing your personal data will be maintained on our servers or those of our IT service providers located in the United States.  Nevertheless, we will process your personal data with the same level of protection as in the EEA and recognise your rights on your personal data you would hold under the GDPR. 

              Where we (or our IT service providers maintaining the servers containing your personal data) transfer your personal data to countries or territories outside the European Economic Area ("EEA"), the laws of such countries or territories may not offer the same level of protection of personal data as are enjoyed within the EEA.  We will ensure that any such international transfers are made in compliance with the GDPR.   For further information, please contact us as set out below.
              1. WHEN WE MAY DISCLOSE YOUR PERSONAL DATA
              We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:
              (a)  to our group companies for the purposes set out in this Notice;
              (b)  to third parties who process your personal data on our behalf such as;

              (i)         Providers of consumer and customer communications in areas such as;

              (A)       Digital and social media communications
              (B)       Customer care
              (C)       Advertising
              (D)       Market Research
              (ii)        Providers of logistical services

              (iii)       Providers of legal services

              (iv)      Providers of IT support services in areas such as;

              (A)       Website development and website management
              (B)       Web site hosting
              (C)       Providers of generic IT services
              (D)       Application development
              (v)       Providers of assurance in areas such;
              (A)       External- and Internal Audit
              (B)       Health, safety, hygiene and technical matters
              (c)  to any third party to whom we assign or novate any of our rights or obligations;
              (d)  to any prospective buyer in the event we sell any part of our business or assets; and/or
              (e)  to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.
              1. HOW WE PROTECT YOUR PERSONAL DATA
              We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorised destruction, loss, alteration, disclosure or access.
              1. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE COLLECT 
              10.1  If you wish us to stop sending you marketing emails, please make use of the option at the end of our marketing emails to you in which you can request that we remove you from our mailing list.
              10.2 If you wish to:
              (a)  update, modify, delete your personal data or obtain a copy of your personal data that we hold; or
              (b)  restrict or stop us from using any of your personal data which we hold,
              you can request this by contacting us as set out below.  
              10.3  In any of the situations listed above, we may request that you prove your identity in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
              1. HOW LONG WILL WE HOLD YOUR PERSONAL DATA FOR
              We will only retain your personal data as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
              1. HOW WE UPDATE OR CHANGE THIS FAIR PROCESSING NOTICE
              This Notice does not form any contractual relationship between you and us, and we may change or update parts of this Notice to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this Notice on this website. 

              You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Notice so you are fully aware of any changes or updates.
              1. HOW YOU CAN CONTACT US
              If you have any queries about the contents of this Notice or your personal data, or wish to make a request in relation to your personal data, please contact us, using the details set out below:
              Post: ZENB US, Inc., 950 Fulton St., Suite A, Chicago, Illinois  60607, USA
              When you make your request please indicate the following;
                • Your name
                • Your email address (or postal address if you previously submitted your postal address to us)
                • The date of your request
                • The date at which you submitted your personal data to us or a description of the specific situation when you provided us with your personal data (a specific situation could be a specific campaign, an event during which we handed out samples, a competition etc.)
                • The nature of your request (i.e. do you want us to correct your data, for us to delete your data, to provide you with a copy etc., etc.)
              1. HOW YOU CAN CONTACT OUR UK REPRESENTATIVE
              We have appointed Ashurst LLP (UK company number OC330252) as our representative in the UK for data protection matters.
              You can contact them using the following email address.  Your message will be forwarded to appropriate members of their data privacy team.
              1. HOW TO LODGE A COMPLAINT TO THE DATA PROTECTION AUTHORITY 
              The protection of your personal data and of our relationship with you is important to us.  Therefore if you have any questions or you think we have breached your data protection rights please contact us as set out above. 
              However, if you are unable to come to a solution with us or want to contact the UK Data Protection Authority to lodge a complaint, please contact the Information Commissioner's Office, which can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.