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Privacy Notice
1. Introduction
Welcome to Zen Internet Limited’s Privacy Notice.
Zen respects your privacy and is committed to protecting your personal information.
This document will tell you how we look after any personal information we collect from you or that
you provide to us. It will also tell you about your privacy rights and how the law protects you.
Please read it carefully to understand our views and practices regarding your personal information.
2. Important information and who we are
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Zen collects and processes your personal
data through your use of this website and our services, which includes any data you may provide
through this website, over the phone or by email when you sign up to our newsletter, purchase a
product or service or take part in a competition.
It is important that you read this privacy notice together with any other privacy notice we may
provide on specific occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data.
CONTROLLER
Zen Internet Limited is the controller and is responsible for your personal data (referred to as ”Zen”,
“we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including any
requests to exercise your legal rights, please contact dataprotection@zeninternet.co.uk using the
details set out below.
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CONTACT DETAILS
Our full details are:
Legal entity Zen Internet Limited
Contact Data Protection Officer
Email address dataprotection@zeninternet.co.uk
Postal address Sandbrook Park
Sandbrook Way
Rochdale
OL11 1RY
Telephone number 01706 902 000
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO),
the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us
in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
Any changes to this privacy notice will be published on our website.
It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every website you visit.
3. The data we collect about you
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).
We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:
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IDENTITY DATA First name, maiden name, last name, username or similar identifier, title
and date of birth.
CONTACT DATA Billing address, delivery address, email address and telephone numbers.
FINANCIAL DATA Bank account and payment card details.
TRANSACTION Details about payments or communications to and from you and other
DATA details of products and services you have purchased from us.
TECHNICAL DATA 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 this website.
PROFILE DATA Your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
USAGE DATA Information about how you use our website, products and services.
MARKETING AND Your preferences in receiving marketing from us and your communication
COMMUNICATIONS preferences.
DATA
IMAGE DATA CCTV and Automatic Number Plate Recognition image data for staff,
tenants and visitors to Zen’s Sandbrook Park headquarters.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal
data in law as this data does not reveal your identity. For example, we may aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature. However, if we
combine or connect Aggregated Data with your personal data so that it can identify you in any way,
we treat the combined data as personal data and it will be used in accordance with this privacy
notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). We do not
collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you
and you fail to provide that data when requested, we may not be able to perform that contract (for
example, to provide you with services). In this case, we may have to cancel a service or order you
have with us and we will notify you of this at the time.
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4. How is your personal data collected?
We use different methods to collect data from and about you including through:
DIRECT INTERACTION
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with
us - or those acting on our behalf - by post, phone, email or otherwise. This includes personal data
you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with our website, we may automatically collect Technical Data about your
equipment, browsing actions and patterns. We collect this personal data by using cookies, server
logs and other similar technologies. Please see our cookie policy for further details.
THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES
We may receive personal data about you from various third parties and public sources as set out
below:
• Technical Data from analytics providers such as Google based inside and outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and
installation services such as Equifax or BT based inside and outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the
Electoral Register based inside the EU.
5. How 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:
• Where we need to perform the contract, we are about to enter into or have entered into
with you.
• Where it is necessary for our legitimate interests (or those of a third-party) and your
interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
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Generally, we do not rely on consent as a legal basis for processing your personal data other than in
relation to sending direct marketing communications to you via email, SMS, post or telephone. We
will always ask for your express opt-in consent before we do so and you have the right to withdraw
consent to marketing at any time by following the opt-out links on any marketing message we send
to you or by contacting us at any time
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.
PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING
INCLUDING BASIS OF LEGITIMATE
INTEREST
To register you as a new (a) Identity Performance of a contract with you
customer (b) Contact
To process and deliver your (a) Identity (a) Performance of a contract with
order including: (b) Contact you
(a) Manage payments, fees (c) Financial (b) Necessary for our legitimate
and charges interests (to recover debts due to us)
(d) Transaction
(b) Collect and recover money
owed to us (e) Marketing and
Communications
To manage our relationship (a) Identity (a) Performance of a contract with
with you which will include: (b) Contact you
(a) Notifying you about (c) Profile (b) Necessary to comply with a legal
changes to our terms or obligation
privacy notice (d) Marketing and
Communications (c) Necessary for our legitimate
(b) Asking you to leave a interests (to keep our records
review or take a survey updated and to study how customers
(c) Providing information to use our products/services)
you to meet our regulatory
obligations
To enable you to partake in a (a) Identity (a) Performance of a contract with
prize draw, competition or (b) Contact you
complete a survey (b) Necessary for our legitimate
(c) Profile
interests (to study how customers
(d) Usage use our products/services, to
(e) Marketing and develop them and grow our
Communications business)
To ask you to complete (a) Identity Necessary for our legitimate
surveys sent by our third-party (b) Contact interests (to understand and improve
service providers the overall service level provided to
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our customers and to monitor how
our third parties are performing
against their service obligations)
To administer and protect our (a) Identity (a) Necessary for our legitimate
business and this website b) Contact interests (for running our business,
(including troubleshooting, provision of administration and IT
data analysis, testing, system (c) Technical services, network security, to
maintenance, support, prevent fraud and in the context of a
reporting and hosting of data) business reorganisation or group
restructuring exercise)
(b) Necessary to comply with a legal
obligation
To deliver relevant website (a) Identity Necessary for our legitimate
content and advertisements to (b) Contact interests (to study how customers
you and measure or use our products/services, to
understand the effectiveness (c) Profile develop them, to grow our business
of the advertising we serve to (d) Usage and to inform our marketing
you strategy)
(e) Marketing and
Communications
(f) Technical
To use data analytics to (a) Technical Necessary for our legitimate
improve our website, (b) Usage interests (to define types of
products/services, marketing, customers for our products and
customer relationships and services, to keep our website
experiences updated and relevant, to develop our
business and to inform our
marketing strategy)
To make suggestions and (a) Identity Necessary for our legitimate
recommendations to you (b) Contact interests (to develop our
about goods or services that products/services and grow our
may be of interest to you (c) Technical business)
(d) Usage
(e) Profile
To monitor activity on and (a) Identity Necessary for our legitimate
around Zen's Rochdale interests (prevention of crime, safety
headquarters using CCTV and security of staff, visitors and
building tenants)
To assist Zen with car park (a) Identity Necessary for our legitimate
access at our Rochdale interests (to assist Zen with car park
headquarters using ANPR access and management)
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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 dataprotection@zeninternet.co.uk
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 above.
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We have established the following personal data control mechanisms:
• Promotional offers and marketing communications from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is how we
decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have purchased services or
requested information from us. Examples of information requests may include requesting a
quote, adding items to your online basket or making enquiries over the telephone or if you
provided us with your details when you entered a competition or registered for a
promotion.
• Third-party marketing
We will get your express opt-in consent before we share your personal data with any
company for marketing purposes.
• Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out
links on any marketing message we send to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal
data provided to us for the provision of services by us to you or other transactions between
us and you.
• Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that some parts
of this website may become inaccessible or not function properly. For more information
about the cookies we use, please see our cookie policy.
• Change of purpose
We will only use your personal data for the purpose we collected it for, unless we consider
that we need to use it for another reason that is compatible with the original purpose. If you
wish to get an explanation as to how the processing for the new purpose is compatible with
the original purpose, please contact dataprotection@zeninternet.co.uk.
If we need to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so.
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Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
6. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in
the table in paragraph 5 above.
EXTERNAL THIRD-PARTIES
• Service providers based inside and outside the EU who provide IT and system
administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who
provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the UK who require
reporting of processing activities in certain circumstances.
• Third-parties to whom we may choose to sell, transfer, or merge parts of our business or
our assets. We may also seek to acquire other businesses or merge with them. If a change
happens to our business, then the new owners may use your personal data in the same
way as set out in this privacy notice.
• Market Research Companies when we ask you to complete surveys or provide other
feedback on our services or our third party’s services.
• Fraud Prevention and Credit Reference Agencies to enable us to protect our rights,
property, customers, or others.
• Specific third parties such as BT and other Service Providers we use to provide services to
you, including the migration of services via the One Touch Switching process.
• Law enforcement agencies, for the prevention of crime.
We require all third-parties to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your personal
data for their own purposes and only permit them to process your personal data for specified
purposes and in accordance with our instructions.
A list of the third parties we share your personal data with in relation to our products and services
can be found here.
INTERNATIONAL TRANSFERS
Occasionally our external third-parties may be based or operate outside the European Economic
Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure the same degree of protection
is afforded to it by ensuring those third-parties enter into a contract with us which oblige them to
give your personal data the same protection it has within the EU.
Please contact us if you want further information on how your personal data may be transferred out
of the EEA.
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7. Data security
We have appropriate security measures in place to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third-parties who
have a business need to know. They will only process your personal data on our instructions, and
they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR
We retain personal information about our customers (including Contact, Identity, Financial and
Transaction Data) for legal and tax purposes as well as our accounting and reporting requirements.
To determine the appropriate retention period for personal data, we will consider the amount and
nature of the personal data, the potential risk of harm any unauthorised use or disclosure may
cause, the purpose for which we process your personal data and whether we can achieve that
purpose through other means. We also consider any applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated
with you) for research or statistical purposes in which case we may use this information indefinitely
without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. You have the right to:
• Request access to your personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and to check that
we are processing it in accordance with the law.
• Request correction of the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though we may need to
verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.
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• Object to processing of your personal data where we are relying on a legitimate interest (or
those of a third-party) and there is something about your particular situation which makes
you want to object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights
and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to
suspend the processing of your personal data in the following scenarios: (a) if you want us to
establish the data's accuracy; (b) where our use of the data is unlawful but you do not want
us to erase it; (c) where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims; or (d) you have objected to our use of
your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you,
or a third-party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the information to perform a
contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal
data. However, this will not affect the lawfulness of any processing carried out before you
withdraw your consent. As we only rely on consent for marketing purposes, if you withdraw
your consent, we will still be able to provide products and services to you.
If you wish to exercise any of the rights set out above, please contact
dataprotection@zeninternet.co.uk.
NO FEE USUALLY REQUIRED
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.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you to confirm your request in writing by email for example or for
further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We aim to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
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10. Glossary of terms
Legitimate Interest The interest of our business in conducting and managing our business
to enable us to give you the best service/product and the best and
most secure experience. We make sure we consider and balance any
potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We
do not use your personal data for activities where our interests are
overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting
dataprotection@zeninternet.co.uk.
Performance of Contract Processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request
before entering into such a contract.
Comply with a legal or Processing your personal data where it is necessary for compliance
regulatory obligation with a legal or regulatory obligation that we are subject to.
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