Privacy Policy

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").If you need it, our company number is 12225182 and our registered office is located at 2nd Fllor, 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. 

In line with these values, this privacy policy tells you what to expect when we collect and use personal data about you.  We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you. 

In this privacy policy, we refer generally to "personal data", which means any data relating to you which identifies you (such as your name) or could indirectly identify you (such as an identification number or online identifier).
 
(C) Who this policy applies to: This policy applies to:

  1. Visitors to our Website; and
  2. Customers and potential customers.
        Depending on our relationship, we will collect and use your information in different ways. 
 
(D) What this policy contains: This privacy policy describes the following important topics relating to your information:

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;

7.  Children;

8.  Where we may transfer your personal data;

9. Risks and how we keep your personal data secure;

10. Links to other websites;

11. Changes to this privacy policy; and

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.

(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal data. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of

1. How we obtain your personal data

1.1  You may provide us with your personal data voluntarily.  We may also receive information about you from third parties such as marketing agencies, market research companies, public and third party websites, our suppliers or our group companies (referred to in this privacy policy as "third party sources" or "suppliers"). 

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, or by posting or commenting on our social media pages (such as, Facebook or Instagram).

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

(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 entry into a survey or competition (including the entry itself, which may be a photo, comment or answer to a question);

(vi)  information provided when you correspond with us;

(vii) any updates to information provided to us;

(viii) the following information 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 about our products and services;

(iii) for improvement and maintenance of our Website and to provide technical support for our Website;

(iv) to ensure the security of our Website;

(v)  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

(vi) 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

(i)   Some pages on our Website use cookies and similar tracking technologies. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. 

(ii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy.

2.2   Customers

(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;

(vii)   to send you service communications; for example, information about your subscription (if you have one), or information about any changes to our Terms of Sale, Terms of Use or to this privacy policy);

(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 suggest similar products to you that you may be interested in 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

3.1 We consider that the legal bases for using your personal data as set out in this privacy policy are as follows:

(a)   our use of your personal data is necessary to perform our obligations under any contract with you (for example, to fulfil an order which you place with us, or to comply with the Terms of Use of our Website which you accept by browsing our Website); or

(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 (for example, to ensure the security of our Website). 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   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 support@zenb.co.uk 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;

(iii)  advertising; and

(iv)  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; and

(d) providers of legal and professional services (including auditors).

4.3    Social media platforms – we include features on our Website which allow you to login to your ZENB account with via certain social media platforms, or 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 provided the features can identify you through some of them.  Indeed, the mere fact that your account with a social network is activated on your device (open session) when you use our Website, can allow that network 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.  Any subsequent use of your personal data by the social media platform will be governed by its own privacy policy, which you should read carefully.  We cannot be responsible for any personal information about you that is collected and stored by those third parties.

4.4   Any third parties with whom we share your personal data are limited (by law and by contract) in their ability to use your personal data. We will always ensure that any third parties with whom we share your personal data are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.5   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;

(c)   in order to enforce or apply our Terms of Use, our Terms of Sale or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(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.

4.6   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.

4.7 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.

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 support@zenb.co.uk 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 or the European Economic Area ("EEA").

(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.   Children

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 support@zenb.co.uk 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 and the EEA (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.

8.2 If we provide any personal data about you to any such non-UK and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:

(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or

(b) in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

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 support@zenb.co.uk 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 support@zenb.com

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

Our Website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal data that we collect or which we receive from third party sources, and we cannot be responsible for personal data about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

11.  Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.

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 support@zenb.co.uk. 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/). 

The practices described in this privacy policy statement are current as at May 2020.