Zilter Technologies Ltd trading as “Zilter” respects your privacy and
is committed to protecting your personal data. This privacy policy
will inform you as to how we look after your personal data when you
visit our website or mobile application (regardless of where you visit
it from) or when you interact with us directly, and tell you about
your privacy rights and how the law protects you. This privacy policy
is provided in a layered format so you can click through to the
specific areas set out below. Please also use the Glossary to
understand the meaning of some of the terms used in this privacy
policy.
1. Important information and who we are
Purpose of this privacy policy:
This privacy policy aims to give you information on how Zilter
collects and processes your personal data through your use of this
website or mobile application, including any data you may provide
through this website when you submit an enquiry, when you respond to
surveys, register to webinars/seminars/events sign up to our
newsletter or purchase a product or service or take part in a
competition.
This website is not intended for children and we do not knowingly
collect data relating to children.
It is important that you read this privacy policy together with any
other privacy policy or fair processing policy we may provide on
specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your
data. This privacy policy supplements other notices and privacy
policies and is not intended to override them.
Controller:
Zilter Technologies Ltd is the controller and responsible for your
personal data (collectively referred to as "Zilter", "we", "us" or
"our" in this privacy policy). We have appointed a data privacy
manager who is responsible for overseeing questions in relation to
this privacy policy. If you have any questions about this privacy
policy, including any requests to exercise [your legal rights], please
contact the data privacy manager using the details set out below.
Contact details:
If you have any questions about this privacy policy or our privacy
practices, please contact our [DPO OR data privacy manager] in the
following ways: Full name of legal entity: Zilter Technologies Limited
Email address: info@zilter.io You have the right to make a complaint
at any time to the Information Commissioner's Office (ICO), the UK
regulator for data protection issues (www.ico.org.uk). We would,
however, appreciate the chance to deal with your concerns before you
approach the ICO so please contact us in the first instance. Changes
to the privacy policy and your duty to inform us of changes We keep
our privacy policy under regular review. This version was last updated
on 24 June 2023. 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.
Third-party links:
This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to
read the privacy policy of every website you visit.
2. The 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, marital status, title, date of birth and gender.
-
Contact Data includes billing address, residential address, email
address and telephone numbers.
- Financial Data includes the financial assessment.
-
Transaction Data includes details about payments to and from you
and other details of products and services you have purchased from
us.
-
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 this website
and/or platform.
-
Profile Data includes your username and password, purchases or
orders made by you, your interests, preferences, feedback and
survey responses.
-
Usage Data includes information about how you use our website,
products and services.
-
Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your
communication preferences.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. 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 website feature. 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.
If you fail to provide personal data:
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 (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the
time.
3. How is your personal data 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 or by corresponding with us by
post, phone, email or otherwise. This includes personal data you
provide when you:
- apply for our products or services;
- create an account on our website or via social media;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; 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 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.
-
Social media platforms such as Facebook, Google, Instagram and
LinkedIn.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most
commonly, we will use your personal data in the following
circumstances:
-
Where we need to perform the contract we are about to enter into
or have entered into with you.
-
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 obligation.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the
types of lawful basis that we will rely on to process your personal
data.
Generally, we do not rely on consent as a legal basis for processing
your personal data although we will get your consent before sending
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.
Purposes for which we will use your personal data:
We have set out below, in a table format, a description of all the
ways we plan to use your personal data, and which of the legal bases
we rely on to do so. We have also identified what our legitimate
interests are where appropriate. Note that 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 contact us
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 in the table below.
Marketing:
We strive to provide you with choices regarding certain personal data
uses, particularly around marketing and advertising.
Promotional offers from us:
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 purchased [goods or services] from us
and you have not opted out of receiving that marketing.
Third-party marketing:
We will get your express opt-in consent before we share your personal
data with any third party for marketing purposes.
Opting out:
You can ask us or third parties to stop sending you marketing messages
at any time by following the opt-out links on any marketing message
sent to you OR by contacting us at any time.
Where you opt out of receiving these marketing messages, 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.
Generalized AI and/or ML models
User data obtained through Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.
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 our cookies 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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the
purposes set out in the table [Purposes for which we will use your
personal data] above.
- External Third Parties as set out in the [Glossary].
-
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.
6. International transfers
We share your personal data within the Zilter organisation and sister
companies, for example chosen IT and service providers based in the
UK, India and other countries. This will involve transferring your
data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a
similar degree of protection is afforded to it 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.
Where we use certain service providers, we may use specific contracts
approved for use in the UK which give personal data the same
protection it has in the UK. Please contact us if you want further
information on the specific mechanism used by us when transferring
your personal data out of the UK.
7. 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. 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.
Please note that Where we have given you (or where you have chosen) a
password which enables you to access certain parts of the Website, you
are responsible for keeping this password confidential. We ask you not
to share a password with anyone.
Security procedures are in place to protect the confidentiality of your data.
We use encryption to protect your information.
8. Data retention
How long will you use my personal data for?
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.
[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 OR set out in the table [Purposes for which we
will use your personal data] above].
OR
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
legal 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection
laws in relation to your personal data. Please click on the links
below to find out more about these rights:
- [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].
If you wish to exercise any of the rights set out above, please
contact us info@zilter.io
No fee usually required:
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.
What we may need from you:
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.
Time limit to respond:
We try to respond to all legitimate requests within one month.
Occasionally it could 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.
10. Glossary
LAWFUL BASIS:
Legitimate Interest means the interest of our business in conducting
and managing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities
where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.
Performance of Contract means processing your data where it is
necessary for the performance of a contract to which you are a party
or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data
where it is necessary for compliance with a legal obligation that we
are subject to.
THIRD PARTIES:
External Third Parties
-
Service providers acting as processors based in the UK or abroad
who provide IT and system administration services.
-
Professional advisers including lawyers, bankers, auditors and
insurers based in in the UK who provide consultancy, banking,
legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the
United Kingdom who require reporting of processing activities in
certain circumstances.
YOUR LEGAL RIGHTS:
You have the right to:
-
Request access to your personal data (commonly known as a "data
subject access request"). This enables you to receive a copy of
the personal data we hold about you and to check that we are
lawfully processing it.
-
Request correction of the personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold
about you corrected, though we may need to verify the accuracy of
the new data you provide to us.
-
Request erasure of your personal data. This enables you to ask us
to delete or remove personal data where there is no good reason
for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your
request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
-
Object to processing of your personal data where we are relying on
a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which
override your rights and freedoms.
-
Request restriction of processing of your personal data. This
enables you to ask us to suspend the processing of your personal
data in the following scenarios:
- If you want us to establish the data's accuracy.
-
Where our use of the data is unlawful but you do not want us
to erase it.
-
Where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend
legal claims.
-
You have objected to our use of your data but we need to
verify whether we have overriding legitimate grounds to use
it.
-
Request the transfer of your personal data to you or to a third
party. We will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us
to use or where we used the information to perform a contract with
you.
-
Withdraw consent at any time where we are relying on consent to
process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to
provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your consent.