Website privacy notice

We are Zulu Group Ltd. We’re a company registered in England and Wales with company number 07754701, whose registered address is at 5 Elstree Gate, Elstree Way, Borehamwood, Hertfordshire, WD6 1JD. In this privacy notice, we will refer to ourselves as ‘we’, ‘us’ or ‘our’. We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.

You can get hold of us in any of the following ways:
a. by emailing us at hello@zulu.group

We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.

We do not have a data protection officer, but if you have any questions about this privacy notice or issues arising from it, you should contact us at hello@zulu.group.

We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them. We may update this privacy notice from time to time. This version was last updated on 31 August 2018.

1.Key definitions

1.1 The key terms that we use throughout this privacy notice are defined below, for ease:

1.2 Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.

1.3 Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks  in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email-marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.)

1.4 Personal Information: in this privacy notice, we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to  information that has been anonymised.

1.5 Special Information – certain very sensitive personal information requires extra  protection under data protection law.  Sensitive data includes information relating to health, racial and ethnic origin, political  opinions, religious and similar beliefs, trade union membership, sex life and sexual  orientation and also includes genetic  information and biometric information.

2.Details of personal information that we collect and hold about you

2.1 Set out below are the general categories and in each case the types of personal  information that we collect, use and hold about you:

General Category
Contact information
Types of Personal Data in that category
This is information relating to your contact details such as name(s), email address, addresses, telephone numbers and company details
Retention Periods
6 years

2.2 The types of personal data we collect about  you may differ from person to person,  depending on who you are and the  relationship between us.

3.Details of special information that we collect and hold about you

3.1 Special information is explained in section  1 above. We do not collect or hold any  special information about you.

3.2 We do not collect information from you relating to criminal convictions or offences.

4.Details of how and why we use personal information

4.1 We are only able to use your personal  information for certain legal reasons set  out in data protection law. There are legal  reasons under data protection law other than  those listed below; but, in most cases, we will use your personal information for the  following legal reasons:
a. Contract Reason: this is in order to  perform our obligations to you under a  contract we have entered into with you;
b. Legitimate Interests Reason: this is where the use of your personal information is  necessary for our (or a third party’s)  legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
c. Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
d. Consent Reason: this is where you have  given us your consent to use your personal  information for a specific reason or specific reasons.

4.2 As explained in section 3 above, there are more sensitive types of personal data, which require higher levels of protection. Where we  process such sensitive types of personal  data, we will usually do this in the  following circumstances:
a. We have your explicit consent;
b. Where it is necessary in relation to legal claims;
c. Where you have made the personal data public.

4.3 So that we are able to provide you with  services, we will need your personal  information. If you do not provide us with the  required personal information, we may be prevented from supplying the services to  you.

4.4 It is important that you keep your personal information up to date. If any of your personal  information changes, please contact us as soon as possible to let us know. If you do not do this, then we may be prevented from  supplying the services to you.

4.5 Where we rely on consent for a specific  purpose as the legal reason for processing  your personal  information, you have the right under data  protection law to withdraw your consent at  any time. If you do wish to withdraw your  consent, please contact us using the details  set out at the beginning of this notice. If we  receive a request from you withdrawing your  consent to a specific purpose, we will stop  processing your personal information for that  purpose, unless we have another legal reason for processing your personal  information – in which case, we will confirm  that reason to you.

4.6 We have explained below the different  purposes for which we use your personal information and, in each case, the legal  reason(s) allowing us to use your personal  information. Please also note the following:
a. if we use the Legitimate Interests Reason  as the legal reason for which we can use your  personal information, we have also explained what that legitimate interest is.

Purpose
To contact you for purposes of exchanging information about us and you or your company in order to evaluate a business transaction
Legal Reason(s) for using the personal information
​Legitimate Interests Reason (in order to offer you other services and/or digital content which helps us to develop our business)

4.7 Sometimes we may anonymise personal  information so that you can no longer be  identified from it and use this for our own purposes. In addition, sometimes we may  use some of your personal information  together with other people’s personal information to give us statistical information for our own purposes. Because this is  grouped together with other personal information and you are not identifiable from that combined data we are able to use this.

4.8 Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider  that the new purpose is compatible with the purpose(s) we told you about. If we want to  use your personal information for a different purpose that we do not think is compatible with the purpose(s) we told you about, then we will contact you to explain this and what legal reason is in place to allow us to do this.

5.Details of how we collect personal information and special information

5.1 We usually collect Identity information and  Contact information directly from you when  you contact us by email, telephone, in writing or otherwise.

5.2 We may receive some of your personal  information from third parties or publicly  available sources. This includes:
a. Identity Information and Contact  Information from publicly available sources  such as Companies House; and
b. Website, Device and Technical  Information from third parties such as  analytics providers (like Google).

6.Details about who personal Information may be shared with

6.1 We may need to share your personal  information with other organisations or people. These organisations include:
a. Other companies in our group (who may might act as joint data controllers or as data processors on our behalf) for purposes of  evaluating a business transaction or  peer-to-peer marketing within the group.

6.2 Depending on the circumstances, the  organisations or people who we share  your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place  contracts that set out the responsibilities and  obligations of us and them, including in  respect of security of personal information.

6.3 We do not sell or trade any of the personal  information that you have provided to us.

7. Details about transfers to countries outside of the EEA

7.1 We do not transfer your personal information outside of the EEA.

8.Details about how long we will hold your personal information

8.1 We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see  section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting  or auditing records or for tax reasons).

9.Automated decision making

9.1 ‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).

9.2 Data protection laws place restrictions upon us if we carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you.

9.3 We do not carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you. If we do decide to do this then we will  notify you and we will inform you of the legal reason we are able to do this.

10.Your rights under data protection law

10.1 Under data protection laws, you have certain rights in relation to your personal  information, as follows:
a. Right to request access: (this is often  called ‘subject access’). This is the right to  obtain from us a copy of the personal  information that we hold about you. We must also provide you with certain other  information in response to these requests to help you understand how your personal information is being used.
b. Right to correction: this is the right to request that any incorrect personal data is  corrected and that any incomplete personal data is completed.
c. Right to erasure: (this is often called the ‘right to be forgotten’).This right only applies  in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
d. Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
e. Right to data portability: this right allows you to request us to transfer your personal information to someone else.
f. Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation that means that you want to object to us processing your personal information. In certain  circumstances, you have the right to object  to processing where such processing  consists of profiling (including profiling for  direct marketing).

10.2 In addition to the rights set out in section 10.1, where we rely on consent as the legal reason for using your personal information,  you have the right to withdraw your consent.  Further details about this are set out in  section 4.5.

10.3 If you want to exercise any of the above rights in relation to your personal  information, please contact us using the details set out at the beginning  of this notice. If you do make a request,  then please note:
a. we may need certain information from  you so that we can verify your identity;
b. we do not charge a fee for exercising  your rights unless your request is unfounded  or excessive; and
c. if your request is unfounded or excessive,  then we may refuse to deal with your request.

11.Marketing

11.1 If you have provided us with your contact  information, you may receive marketing from  us about similar goods and services where  either you have consented to this, or we have  another legal reason by which  we can contact you for marketing purposes.

11.2 However, we will give you the opportunity to manage how or if we market to you. In any email that we send to you, we provide a link to either unsubscribe or opt out, or to change your marketing preferences. To change your  marketing preferences, and/or to request that  we stop processing your personal  information for marketing purposes, you can  always contact us on the details set out at the  beginning of this notice.

11.3 If you do request that we stop marketing to  you, this will not prevent us from sending  communications to you that are not to do with marketing (for example in relation to services that you have purchased from us).

11.4 We do not pass your personal information on  to any third parties for marketing purposes.

12.Complaints

12.1 If you are unhappy about the way that we  have handled or used your personal  information, you have the right to complain to  the UK supervisory authority for data protection, which is the Information  Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in  respect of our handling or use of your  personal information, so that we have the  opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.

13.Third-party websites

13.1 Our website may contain links to third-party websites. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices  to understand how your personal information is collected and used by them.