UPDATED AUGUST 2021
Overview – the key information you should be aware of
(A) Who we are: We are ZENB UK Ltd, a company registered in England and Wales. We own and operate the Website, http://.zenb.co.uk, including the mobile version of it (the "Website"); we also operate pages on various social media channels. If you need it, our company number is 12225182 and our registered office is located at 2nd Floor, Building 10 Chiswick Park, 566 Chiswick High Road, Chiswick, London, United Kingdom, W4 5XS. ZENB UK Ltd is the controller of your personal data, and is responsible for your personal data. ZENB US, Inc. is also a controller in some, more limited, respects. All references in this policy to "ZENB", "our", "us" or "we" refer to ZENB UK Ltd, and ZENB US, Inc. – our parent company – as appropriate.
(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal data. We also want you to know your rights in relation to your information which you can find in section 6.
(C) Who this policy applies to: This policy applies to:
1. Visitors to our Website and social media pages; and
2. Customers and potential customers.
Depending on our relationship, we will collect and use your information in different ways.
1. How we obtain your personal data;
2. Collection of your personal data and how we use it:
3. Our legal basis for using your personal data;
4. How and why we share your personal data with others;
5. How long we store your personal data;
6. Your rights;
8. Where we may transfer your personal data;
9. Risks and how we keep your personal data secure;
10. Links to other websites;
12. Further questions and how to make a complaint.
(E) Your rights to object: You have various rights in respect of our use of your personal data as set out in section 6. Two of the fundamental rights to be aware of are that:
1. you may ask us to stop using your personal data for direct marketing purposes (for example, by clicking on the unsubscribe link in our emails). If you exercise this right, we will stop using your personal data for this purpose.
2. you may ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our, or another person's, legitimate interest.
The detail – the key information you should be aware of
1. How we obtain your personal data
1.2 You may give us personal data about yourself by establishing an account with us, ordering products or services from us, registering to receive our newsletter or email communications, participating in a survey or competition run by us, submitting an enquiry or request to us using the forms on our Website, by contacting us by phone, email or other means, by posting or commenting on our social media pages (such as, Facebook or Instagram) or by submitting material or content to the Website or our social media pages (including any reviews of our products or recipe submissions).
2. Collection of your personal data and how we use it
Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use your personal data.
2.1 Visitors to our Website and social media pages
(a) What personal data we collect about you
We, or third parties on our behalf, may collect and use the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your social media username;
(vi) your entry into a survey or competition (including the entry itself, which may be a photo, comment or answer to a question);
(vii) information provided when you submit material or content to the Website or to any of our social media pages (including, for example, your image or location);
(viii) information provided when you correspond with us;
(ix) any updates to information provided to us;
(x) the following information is created and recorded automatically when you visit our Website:
(A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the Website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal data to administer our Website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and
(B) Information about your visit and your behaviour on our Website (for example, the pages that you click on). This may include the Website you visit before and after visiting our Website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.
(b) How we use your personal data
We will collect, use and store the personal data listed above for the following reasons:
(i) to allow you to access, use and place orders via our Website;
(ii) to receive, and respond to, enquiries from you through the Website or through our social media pages about our products and services;
(iii) to receive and use material or content that you choose to submit to us on the Website or on our social media pages (such as reviews of our products or recipe submissions), to share those materials or content on our Website, social media pages and in other marketing and promotional materials;
(iv) for improvement and maintenance of our Website and to provide technical support for our Website;
(v) to ensure the security of our Website;
(vi) to recognise you when you return to our Website, to store information about your preferences, and to allow us to customise the Website according to your individual interests; and
(vii) to evaluate your visit to the Website and prepare reports or compile statistics to understand the type of people who use our Website, how they use our Website and to make our Website more intuitive.
(c) A word about cookies
(ii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy and the Privacy Preference Center on the Website.
(a) What personal data we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your account information (if you choose to set up an account with us);
(vi) information about what products you have purchased from us, and information relating to the shipping of those products;
(vii) your product preferences;
(viii) your email subscription preferences;
(ix) information about how you engage with our emails; including whether they are delivered to you, whether you open them, whether you choose to learn more about what's happening at ZENB (for example, by clicking on a link in our email) and if you ask us not to contact you anymore (by clicking on the unsubscribe option included in our marketing emails);
(x) review data, when you write a personal testimonial or review about our products and post it on our Website;
(i) information provided when you correspond with us;
(ii) any updates to information provided to us;
(iii) information you provide to help us to improve our products and services; for example, if you complete one of our surveys or questionnaires; and
(iv) the information set out in section 2.1, in relation to Website users.
(b) What about payment information?
When you make purchases through our Website, we may request certain personal data from you. Note that although you may submit credit card information in connection with making a purchase, ZENB does not collect or store your credit card information. If you choose to make an online purchase from ZENB, you may be given the option to make payment directly through a third-party payment provider used by ZENB. We do not control, review or store your credit card information when you engage in a payment transaction with us.
(c) How we use your personal data
We will collect, use and store the personal data listed above for the following reasons:
(i) to provide you with our products and services;
(ii) to create and administer your ZENB account;
(iii) to deal with any enquiries or issues you have about our products or services;
(iv) for fraud prevention purposes;
(v) to manage, develop and improve our product range, service and our Website; and
(vi) to display any testimonials or reviews you leave on our Website for other customers to see;
(viii) to send you promotional and marketing materials by e-mail, unless you have told us that you'd rather not hear from us; and
(ix) to determine the effectiveness of our communications, promotional campaigns and advertising.
(d) We combine the information we collect about you to analyse and enhance that information; in particular to deliver targeted marketing and advertising to you and to understand which products appeal to our customers generally.
(e) Information we need to provide services to you. We need certain types of personal data so that we can provide our products and services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal data, or if you ask us to delete it, you may no longer be able to receive or access our products and services.
2.3 Whatever our relationship with you is, we may also collect, use and store your personal data for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal data, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal data for these purposes where it is in our legitimate interests for customer services purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal data for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
2.4 Further processing
Before using your personal data for any purposes which fall outside those set out in this section 2, we will undertake an analysis to establish if our new use of your personal data is compatible with the purposes set out in this section 2. Please contact us using the details in section 12 if you want further information on the analysis we will undertake.
3. Legal basis for use of your personal data
(b) our use of your personal data is necessary for complying with our legal obligations; or
(c) where neither (a) nor (b) apply, use of your personal data is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
(i) run, grow and develop our business;
(ii) build relationships with our customers;
(iii) improve our products and services;
(iv) operate and improve our Website;
(v) detect and prevent fraud;
(vi) keep our Website and IT systems secure;
(vii) carry out marketing and market research; and
(viii) for internal group administrative purposes.
3.2 Some of the specific situations in which our use of your personal data is necessary for our legitimate interests include to send you e-mail marketing if you are a customer of ours (assuming you haven't asked us to stop), to share your personal data with social media platforms (as described below) and to use your personal data to determine the effectiveness of our campaigns.
3.3 In some circumstances, you may also have given your consent to our use of your personal data; for example, where you choose to share materials or content with us on the Website. If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at firstname.lastname@example.org and we will stop doing so.
4. How and why we share your personal data with others
4.1 We may share your personal data with our group companies where we share IT systems and processes and for internal administrative purposes, when it is in our legitimate interests to do so (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
4.2 We will share your personal data with the following third parties or categories of third parties:
(a) providers of consumer and customer communications in areas such as:
(i) digital and social media communications;
(ii) customer care; and
(iii) marketing research;
(b) providers of logistical services;
(c) providers of IT services in areas such as:
(i) website development and website management;
(ii) website hosting;
(iii) cloud service providers;
(iv) providers of data analytics tools;
(v) providers of generic IT services;
(vi) application development; and
(vii) payment processors;
(d) social media platforms (for more, see section 4.7 below); and
(e) companies that assist us in our marketing, advertising and promotional activities, such as, to help us with our mobile marketing and to track, measure and analyse the success of our advertising and marketing (for more, see section 4.8 below); and
(f) providers of legal and professional services (including auditors).
4.4 We will also disclose your personal data to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop our business:
(i) if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
(ii) if substantially all of our or any of our group companies' assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
(b) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(d) to protect the rights, property, or safety of ZENB, our staff, our customers or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection.
4.5 We may also disclose and use anonymised, aggregated reporting and statistics about users of our Website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
4.6 Save as expressly detailed above, we will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so.
Social media and personalised advertising
4.7 Social media platforms:
We include features on our Website which allow you to easily link to our social media pages or share our content with others by clicking on social media sharing buttons Even if you do not use those features when using our Website, the social networks that provide the features can identify you through some of them. The fact that your account with a social network is activated on your device (open session) when you use our Website, can allow that platform to monitor your navigation of our Website. Our use of those features means that we will share certain personal data with those social media providers, and they will share certain personal data with us.
We also share your personal data with social media or other similar platforms, so that you and other people can see relevant content on that platform. For example, we may use Facebook Custom Audiences and share your e-mail address in a protected format with Facebook so that we can: include you in a custom audience that we will serve relevant advertising content to on Facebook, or create an audience of other Facebook users based on the information Facebook holds about you.
Those platforms' use of your personal data is governed by their own privacy policies, which you should read carefully. We cannot be responsible for any personal data about you that is collected and stored by those third parties.
4.8 Personalised advertising:
We also use personalised online advertising to tell you about our Website and our products. This means that, after visiting our Website, you may see advertising for our Website and/or our products when you are on other third-party websites (including Google and YouTube).
5. How long we store your personal data
We keep your personal data for no longer than necessary for the purposes for which the personal data is processed. The length of time for which we retain personal data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
6. Your rights
6.1 You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at email@example.com at any time. You have the following rights:
(a) Right of access. You have a right of access to any personal data we hold about you. You can ask us for a copy of your personal data; confirmation as to whether your personal data is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom.
(b) Right to update your information. You have a right to request an update to any of your personal data which is out of date or incorrect. If you have an account on our Website, you may access, review and update the information you provided to us at any time by signing into your account. Please ensure that any personal data you provide to us is accurate and up-to-date.
(c) Right to delete your information. You have a right to ask us to delete any personal data which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.
We will pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 12.
(d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal data in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 12.
We will pass your request onto other recipients of your personal data unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 12.
(e) Right to stop marketing: You have a right to ask us to stop using your personal data for direct marketing purposes. If you exercise this right, we will stop using your personal data for this purpose.
(f) Right to data portability: You have a right to ask us to provide your personal data to a third party provider of services.
This right only applies where we use your personal data on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(g) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal data where we process your personal data on the basis of our or another person's legitimate interest.
6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
7.1 Our Website and services are not directed at children and we do not knowingly collect any personal data from children.
7.2 If you are a child and we learn that we have inadvertently obtained personal data from you from our Websites, or from any other source, then we will delete that information as soon as possible.
7.3 Please contact us at firstname.lastname@example.org if you are aware that we may have inadvertently collected personal data from a child.
8. Where we may transfer your personal data
8.1 Your personal data may be used, stored and/or accessed outside the UK (including in the U.S. and Canada) by other members of our group or our suppliers. Further details on to whom your personal data may be disclosed are set out in section 4.
8.3 Further details on the steps we take to protect your personal data in these cases is available from us on request by contacting us by email at email@example.com at any time.
9. Risks and how we keep your personal data secure
9.1 The main risk of our processing of your personal data is if it is lost, stolen or misused. This could lead to your personal data being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
9.2 For this reason, ZENB is committed to protecting your personal data from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal data, including through use of appropriate organisational and technical measures.
9.3 In the course of provision of your personal data to us, your personal data may be transferred over the internet. Although we make every effort to protect the personal data which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to our Website and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access to it.
9.4 We encourage you not to include sensitive personal data in any emails you send to us. Additionally, please do not send credit card numbers or other payment information to us via email. We will not contact you by mobile/text messaging or email to ask for your personal data or credit card details. If you receive this type of request, you should not respond to it. We also ask that you please notify us at firstname.lastname@example.org.
9.5 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
10. Links to other websites
12. Further questions and how to make a complaint
12.1 If you have any queries or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights in relation to your personal data, you can contact us through this page: https://zenb.co.uk/pages/contact or by e-mail on email@example.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data. You may also make a complaint to the Information Commissioner's Office (https://ico.org.uk/).