UPDATED NOVEMBER 2023
Overview – the key information you should be aware of
(A) Who we are:
We are ZENB UK Ltd, registered in England and Wales, and our company number is 12225182 with registered offices at 2nd Floor, Building 10 Chiswick Park, 566 Chiswick High Road, Chiswick, London, United Kingdom, W4 5XS. ZENB UK Ltd. is the controller and responsible for your personal data. All references in this Policy to "ZENB", "our", "us" or "we" refer to ZENB UK Ltd and ZENB US, Inc. as appropriate.
We are a food retailer of plant based products and we own and operate the Website, https://.zenb.co.uk, including the mobile version of it (the "Website"); we also operate pages on various social media channels.
(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 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.
(C) This Policy contains:
1. How we collect your personal data;
2. The personal data we collect about you;
3. How we use your personal data;
4. We share your personal data with others;
5. How long we store your personal data;
6. Your rights;
7. Our Website is not intended for 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 our Policy; and
12. Further questions and how to make a complaint.
(D) 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:
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.
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.
(E) What you need to do and your confirmation to us:
Please read this Policy carefully to understand how we handle your personal data. By engaging with us in the ways set out in this Policy, you confirm that you have read and understood the entirety of this Policy, as it applies to you.
1. How we collect your personal data
1.1 You 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 Policy as "third party sources" or "suppliers").
1.2 You provide us with your personal data 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. The personal data we collect about you
2.1 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).
2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes first name, last name, social media username,
(b) Contact Data includes billing address, delivery address, email address, and telephone number.
(c) Financial Data includes payment card details.
(d) Transactional Data includes details about payments to and from you and other details of products and services you have purchased from us.
(e) Technical Data includes internet protocol address, login details, location, browser type and version, browser plug-in types, operating system, and platform details.
(f) Profile Data includes your login details and password, purchases or orders made by you, your entry into a survey or competition (including images), your interests, preferences, feedback, recipe submissions, and review, testimonial, and survey responses.
(g) Usage Data includes information about how you use our website, products and services.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us or our third parties and your communication preferences.
3. How we use your personal data
3.1 We have set out below, in a table format, a description of the type of personal data we collect and all the ways we plan to use your personal data, including 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.
To register you as a new customer
Performance of a contract
To process and deliver your order
e) Marketing and Communications
Performance of a contract
To manage our relationship with you which willinclude:
a) Notifying you about changes to our terms or Policy
b) Asking you to leave a review or take a survey
d) Marketing and Communications
a) Performance of a contract with you
b) Necessary to comply with a legal obligation
c) Necessary for our legitimate interests (tokeep our records updated and to study how customers use our products/services)
To enable you to participate in a promotion orcomplete a survey, review, or testimonial
e) Marketing and Communications
a) Performance of a contract with you
b) Necessary for our legitimate interests (tostudy how customers use our products/services, to develop them and grow ourbusiness)
To administer and protect our business and thisWebsite (including troubleshooting, data analysis, testing, systemmaintenance, support, reporting and hosting of data)
a) Necessary for our legitimate interests (forrunning our business, provision of administration and IT services, networksecurity, to prevent fraud and in the context of a business reorganisation orgroup restructuring exercise)
b) Necessary to comply with a legal obligation
To deliver relevant Website content andadvertisements to you and measure or understand the effectiveness of theadvertising we serve to you
a) Including information about how you engagewith our emails
e) Marketing and Communications
Necessary for our legitimate interests (tostudy how customers use our products/services, to develop them, to grow ourbusiness and to inform our marketing strategy)
To use data analytics to improve our Website,products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (todefine types of customers for our products and services, to keep our Websiteupdated and relevant, to develop our business and to inform our marketingstrategy)
To make suggestions and recommendations to youabout goods or services that may be of interest to you
f) Marketing and Communications
Necessary for our legitimate interests (todevelop our products/services and grow our business)
3.2 A word about cookies:
3.3 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.
3.4 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.
3.5 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.
3.6 Further processing:
Before using your personal data for any purposes which fall outside those set out in this section, 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. Please contact us using the details in section 12 if you want further information on the analysis we will undertake.
4. How 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). The companies under our group include:
(a) ZENB US Inc.;
(b) ZENB Japan Co., Ltd.;
(c) Mikan Euro Ltd.;
(d) Mizkan Euro Partners Limited;
(e) Mizkan Euro Holdings Limited;
(f) Mizkan Holdings Co., Ltd.;
(g) Mizkan J Plus Holdings Co., Ltd.;
(h) Mizkan Co., Ltd.; and
(i) Mizkan Partners Co., Ltd.
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 services;
(iv) Data analytics tools;
(v) Generic IT services;
(vi) Application development; and
(vii) Payment processors;
(d) Social media platforms (for more, see section 4.7 below);
(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).
4.3 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 Policy and applicable laws.
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 can contact us at firstname.lastname@example.org and we will stop doing so.
Social media and personalised advertising
4.7 Social media platforms:
We 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 Meta Custom Audiences and share your e-mail address in a protected format with Meta so that we can: include you in a custom audience that we will serve relevant advertising content to on Meta, or create an audience of other Meta users based on the information Meta 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 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. In most circumstances, we will not retain your data for more than 5 years after the end of your customer relationship with us.
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.
(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.
(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. Our Website is not intended for 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 Website, 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 US, Japan, 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 When we provide any personal information about you to any non-UK members of our group or service providers, we take appropriate steps to protect your privacy and implement reasonable security measures to protect your personal data. These measures may include the following:
(a) Ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, which means that the recipient country is deemed to provide adequate protection for such personal data; or
(b) Ensuring that appropriate safeguards are in place, e.g. by entering into regulation mandated contracts with our data processors that require them to treat personal data in a manner that is consistent with this Policy.
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 We are 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.
9.2 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.
9.3 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.
9.4 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 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 Policy
We may update our Policy from time to time. Any changes we make to our Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our 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 email@example.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data.
12.2 You may also make a complaint to the Information Commissioner's Office (https://ico.org.uk/) or the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws had taken place.
The practices described in this Policy are effective as of November 2023. We last updated our Policy in Novemberr 2023 to give more detail to what personal data we collect, where we transfer your personal data and which third parties we share your personal data with as well as restructuring the Policy for your usability.