As the operators of the website [www.zozter.com] and of the Zozter App (“Platform”), Zozter Limited ("We", “Us”) is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (“Policy”) (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation (“GDPR”, from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the “Data Protection Laws”) the Data Controller is Zozter Limited.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information from you:
Information that you provide by filling in forms on the Platform or filing in forms as part of the registration process. This includes information provided at the time of registering to use the Platform, subscribing to our service, completing your online profile and online business card or requesting further information or services. We may also ask you for information when you report a problem with the Platform.
Specifically, personal details such as name, email address, job title, location data (e.g. precise location from your mobile GPS), phone number, driving licence number, passport number, visa number, educations details, qualifications, awards or any information input or contained in any attachments you upload (e.g. your resume) by when using the Platform, using our Services.
If you contact Us, We may keep a record of that correspondence.
We will collect information about you when you send, receive or engage with messages using the Platform, or connect with other Users.
Details of your visits to the Platform including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
Automatically update the Zozter application on your device.
The provision of your name, address, e-mail address, contact number, gender, company name, business sector, department, designation, is required from you to enable Us to register you as a User of the Platform and allow you access to all of the Service, which includes advertising on our Platform. The provision of your name, e-mail address, details of your friend’s name and their e-mail address is required from you if you wish to refer them to Us. Your company name, company website, company logo, contact numbers, name, photo, job position, e-mail address, unique ID and address is required to create an online business card. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
We use information held about you in accordance with the following “legal bases” and for the following purposes:
To provide you with our Platform and to carry out any other obligations arising from any contracts entered into between you and Us. We rely on “performance of a contract with you” as the legal basis for this processing.
To notify you about changes to our services and to provide you with information regarding our services and any support. We rely on “performance of a contract with you” as the legal basis for this processing.
To ensure that content on the website is presented in the most effective manner for you and for the device(s) you use to access and view the website. We rely on “legitimate interest” as the legal basis for this processing, and the legitimate interest is the maintenance and improvement of our website for the benefit of all our users.
Where you have contacted us via the Platform, e-mail and telephone, we rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer”.
We may use information held about you to promote our products and services that may be of interest to you. We will only do this where we reasonably believe that our services may be of interest to you and we rely on “legitimate interest” to promote our products and services to you.
If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the registration form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; (iii) unsubscribe from our electronic communications by un-ticking the relevant box on the Platform or (iv) inform Us at any time by contacting Us at the contact details set out below.
We may pass your name, email address, job title, location data (e.g. precise location from your mobile GPS), phone number, driving licence number, passport number, visa number, educations details, qualifications, awards or any information input or contained in any attachments you upload (e.g. your resume)to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
Payment is handled separately, and securely, through the payment processor you have selected during checkout (“Payment Processor”). Your payment card details are never collected by Us. If you want to find out more about how the Payment Processor processes your personal data, you can refer to their own privacy notice.
We may also disclose your personal data to third parties:
in the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions and other agreements; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the Website; or
in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Where We process payment transactions, these will be encrypted using SSL technology. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing the relevant page of the Platform. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold any information you input or contained in any attachments you upload (e.g. your resume) such as such as name, email address, job title, location data (e.g. precise location from your mobile GPS), phone number, driving licence number, passport number, visa number for as long as you have registered an account with Us, unless you notify Us otherwise or terminate your account.
Where you have placed an ad on the Platform, We will hold your contact, advert and enquiry details for as long as you have registered an account with Us, unless you notify Us otherwise or terminate your account.
Where you have contacted us via the Platform, e-mail and telephone and you are not a registered user We will hold your contact and enquiry details for 30 days once your enquiry has been completely dealt with.
We will retain any financial data (where payment has been made for our services) for 7 years in accordance with applicable tax laws.
Account De-activation and Deletion
When your account is temporarily deactivated, others will not be able to see your profile or search for you but some information may remain visible, such as content you have posted in a group.
If you have chosen to delete your account, shared information with others, such as posting updates, reviews or mailing users on the Platform will remain visible after your account has been deleted. Such content will appear as posted from an unknown source.
It may take up to 30 days to delete your data on our Platform. Further, you may continue to be visible in search engine results and by other users until those search engines have refreshed their cache and those users have refreshed their cookies.
Where we store your personal data
All information We hold about you is stored on secure servers in the United States.
It may also be processed by staff operating outside the EEA who work for Us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. To obtain a copy of such safeguards please contact Us (see ‘Contact’ below).
We will not otherwise transfer your personal data outside of the UK or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address,
require Us to correct any mistakes in your information which We hold,
require the erasure of personal data concerning you in certain situations,
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations,
object at any time to processing of personal data concerning you for direct marketing,
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you,
object in certain other situations to our continued processing of your personal data,
otherwise restrict our processing of your personal data in certain circumstances,
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email, call or write to Us,
let Us have enough information to identify you,
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill),
let Us know the information to which your request relates.
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner.
We may collect information about your mobile phone, computer or other device from which you access the Platform including where available your device, operating system and browser type, for systems administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
A cookie is a small file of letters and numbers that We store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
The cookies We use include:
“Analytical” cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps Us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.
“Strictly necessary” cookies. These are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform.
“Functionality” & “Preference” cookies. These are used to recognise you when you return to our Platform. This enables Us to personalise our content for you, greet you by name and remember your preferences.
“Persistent” cookies. These are used to recognise you and remembers your information and settings whenever you visit us.
“Targeting” & “Advertising” cookies. These cookies record your visit to our Platform, the pages you have visited and the links you have followed to our affiliates Platforms. We will use this information to make our Platform, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
“Session” cookies. These cookies are stored temporarily and are not retained after the browser is closed.
“Security” cookies. These cookies help identify and prevent security risks. For example, we may use these cookies to store your session information to prevent others from changing your password without your username and password.
You can find more information about the individual cookies We use and the purposes for which We use them in the table below:
Expiry of Cookie and Further Information
This cookie enables us to determine whether or not you have visited our Platform previously.
This cookie is what’s called a “persistent” cookie, as in, it never expires (technically, it does expire…in the year 2038…but for the sake of explanation, let’s pretend that it never expires, ever). This cookie keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred. Google Analytics uses the information from this cookie to calculate things like Days and Visits to purchase.
The B and C cookies are brothers, working together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site. __utmb expires at the end of the session. __utmc waits 30 minutes, and then it expires. You see, __utmc has no way of knowing when a user closes their browser or leaves a website, so it waits 30 minutes for another pageview to happen, and if it doesn’t, it expires.
This cookies enables us to establish how you reached our Platform e.g. through a link; from another Platform or by typing in the Platform URL
__utmz keeps track of where the visitor came from, what search engine you used, what link you clicked on, what keyword you used, and where they were in the world when you accessed a website. It expires in 15,768,000 seconds – or, in 6 months. This cookie is how Google Analytics knows to whom and to what source / medium / keyword to assign the credit for a Goal Conversion or an Ecommerce Transaction. __utmz also lets you edit its length with a simple customization to the Google Analytics Tracking code.
If you are making use of the user-defined report in Google Analytics, and have coded something on your site for some custom segmentation, the __utmv cookie gets set on the person’s computer, so that Google Analytics knows how to classify that visitor. The __utmv cookie is also a persistent, lifetime cookie.
Third Party Cookies
Please note, we also work with a number of analytics partners, including Google Analytics to help us analyse how you use the Platform, market and advertise our services to you and on third party websites, help us detect or prevent fraud or conduct risk assessments, or collect information about your activities on the Platform, other sites, and/or the ads you have clicked on. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here.
Third parties may also use tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Platform and on other websites and online services. For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. We do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to [firstname.lastname@example.org] write to Us at [Zozter Ltd, 37 Northfield Road, Heston, Hounslow, TW5 9JQ, UK].