GDPR is finally here and we’re already seeing stories about corporate US websites being shut down for failing to get their ducks in a row re: data compliance. To us, that’s really important. It always has been. So, to assure all of our clients, suppliers and everybody else who makes up the Zaboura team that data is safe in our hands, we’ve updated a couple of things:
Zaboura Consultancy Limited (but we will refer to ourselves using the word “we” and related words such as “us” and “our” in this privacy notice (this is where we are registered)
Place of incorporation
UK (this is where we are registered)
75 Kenton Street, London, WC1N 1NN
Operating Address :
259 Linen Hall, 162 Regent Street, London W1B5TE
Under data protection law, we are considered to be a “controller”. As a controller, we are responsible for, and control the processing of your personal data.
Section 2- What Information we collect from you:
In the course of our business as a communications and marketing company we collect the following personal data when you provide it to us:
- personal details, such as:
– name and title
- contact data, such as:
– billing address
– e-mail address
– telephone and mobile number(s)
- biographical data from job applications and CVs, such as:
– institutions attended
– academic and other results gained
– employment history
– any other personal information you provide
- transaction data, such as:
– details about payments to and from you
– details of services you have purchased from us
- technical data, such as:
– 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 our website
- usage data, such as:
– information about how you use our website and services
- marketing data, such as:
– any preferences in receiving marketing and communications.
- We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply. It comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.
We also do not collect information about criminal convictions or offences.
Section 3 – How do we collect personal data?
We obtain personal data from sources as follows:
- – directly from you when you interact with us, for example when you:
– request information
– write to us
– attend an event
– enter a competition
– give us feedback
– apply for a job or internship or send a CV
- – if others provide your details (for example, if you are copied on an e-mail that is sent to us, and your e-mail address identifies you, we will have collected your personal data). If you are providing another person’s details, please ensure you have that person’s explicit consent to do so.
- – from subscription services that you have provided consent to:
- – Response source
- – Gorkana
- – Cision
Section 4 – How do 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:
- – to perform a contract we are about to enter into, or have entered into with you
- – if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
- – where we need to comply with a legal or regulatory obligation
In order to process personal data, we must have a lawful reason (sometimes called a lawful basis). We always ensure that this is the case, and we set out our lawful bases below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests.
We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.
Please contact us if you would like more information on this, and on situations in which more than one lawful basis applies.
If you are our customer or applying for a job, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our services to you:
- – to identify you
- – to respond to your enquiries
- – to the extent necessary to provide pre-contractual information about our services
- – to provide our services
- – to carry out billing and administration activities
- – to evaluate your job application and take any next steps, and to evaluate your suitability for roles where you have asked to be considered for future opportunities
We process your personal information for our legitimate business purposes, which include the following:
- – to conduct and manage our business
- – to enable us to carry out our services
- – to ensure our website and systems are secure (for example, by conducting security penetration tests on our website to ensure our security tools are effective)
- – to analyse, improve and update our services for the benefit of our customers
- – to deal with complaints
- – to let you know about our services, promotions or events that we consider may be of interest to you (and which may be tailored to your interests as construed): we carry out this processing on the legal basis that we have a legitimate interest in marketing our services, and only to the extent that we are permitted to do so by applicable direct marketing laws. Please see section 8 below for further information about our marketing activities and regarding your right to opt out
Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.
Compliance with Laws
We may process your personal data in order to comply with applicable laws (for example, if we are required to cooperate with an investigation pursuant to a court order).
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via e-mail where this is not otherwise permitted. You have the right to withdraw consent to marketing at any time. This will not affect the lawfulness of processing that took place prior to the withdrawal of consent.
We will always be clear whenever we intend to process on the basis of consent, and we will process lawfully and only for the purpose for which consent was given.
Section 5 – Do we share your personal data?
We may provide your personal data to the following recipients for the purposes set out in this notice:
- – our service providers, including:
– e-mail and mail service providers
– technical and support partners, such as the companies who host our website and who provide technical support and back-up services
– recruitment service providers
- – merger or acquisition partners, to the extent that sharing your personal data is necessary
- – law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority (where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety)
- – any other parties, where we have your specific consent to do so
Section 6 – Do you have to provide personal data – and if so why?
To form a contract with you, we will need some or all of the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, it will not be possible to perform that contract.
If you sign up to any mailing list, you will have to provide certain personal data. Of course, you may decide to stop receiving our mailings at any time.
Section 7 – For how long will your personal data be kept?
We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.
Section 8 – Marketing
We may store your contact details, and carry out marketing profiling activities, for direct marketing purposes. If you have given your consent, or if we are otherwise permitted to do so, we may contact you about our services that may be of interest to you. You will be given the opportunity to opt out each time you are contacted. Additionally, you may opt out at any time by contacting us using the details in section 15 below.
Section 9 – Do we transfer personal data outside the EEA?
Although we are based in England, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area, if we consider it necessary or desirable for the purposes set out in this notice.
In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission “adequacy decision” applies (this is a decision from the European Commission confirming that adequate safeguards are in place in that location for the protection of personal data), or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, or by the adoption of EU-US Privacy Shield.
For more information, please contact us using the details in section 15 below.
Section 10 – How do we keep your personal data secure?
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our authorised employees and third parties processing data on our behalf have access to your personal data.
We take all reasonable steps to keep your data safe and secure, and to ensure the data is accessed only by those who have a legitimate interest 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 us. Any transmission over the internet is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Please contact us using the details in section 15 below if you would like further information about this.
Section 11 – Your Information Rights
We draw your attention to your following rights under data protection law:
- – right to be informed about the collection and use of your personal data
- – right of access to your personal data, and the right to request a copy of the information that we hold about you as well as supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
- – right to have inaccurate personal data that we process about you rectified– we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us – and please also update us if this information changes
- – right of erasure– in certain circumstances you have the right to require us to block, erase or destroy personal data that we process about you
- right to object to, or restrict:
– processing of personal data concerning you for direct marketing
– decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you (however, we do not currently take automated decisions)
– in certain other situations, our continued processing of your personal data
- the right of portability of your data in certain circumstances
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 may refuse to comply with your request in these circumstances.
Please contact us using the details in section 15 below if you would like to know more about, or to exercise these rights.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/
Section 12 – Cookies
Section 13 – Changes to this privacy notice
We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.
Section 14 – How you can complain
We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have a right to raise a concern with our supervisory authority, the Information Commissioner’s Office: https://ico.org.uk/
However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details in section 15 below, so that we have an opportunity to resolve it.
Section 15 – Contacting us
If you would like to contact us about this notice or wish to receive further information about any aspect of it, our details are as follows:
Zaboura Consultancy Ltd
259 Linen Hall
162 regent Street
+44 (0) 203 5880804
End of Privacy Notice