Privacy Notice

Scope of our privacy policy

This privacy policy explains how we use any information we collect about you, how you can tell us if you prefer to limit the use of that information and the procedures that we have in place to safeguard your privacy.

For the purpose of the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (EU) 2016/679 the data controller is our Customer.

All changes to this policy will be communicated with affected parties.

Background:

Zinc Digital Business Solutions Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our data subjects and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information about Zinc

Zinc Digital Business Solutions Limited Trading as Zinc Systems.
A Limited Company registered in England under company number 053235293.
Registered address: 22-24 Harborough Road, Northampton NN2 7AZ
Main trading address: 33 Bedford Road, Little Houghton, NN7 1AB.
VAT number: 849353004
Data Protection Manager: Stephen Shackell.
Email address: stephen.shackell@zinc.systems.
Telephone number: 01604 598989.
Postal address: 33 Bedford Road, Little Houghton, NN7 1AB.
We are regulated by Information Commissioner’s Office.

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our or collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

5. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.

Data Collected	How We Collect the Data
Prospective Customers: Contact information including your full name, Company name, email address, telephone number.	Through a number of means, such as if you reach out to us as a prospective customer or taking interest in coming to work at Zinc Systems. You can contact us through our website, other media such as LinkedIn or through other direct contact with our team.
Customers: Contact information including your full name, Company name, email address, telephone number, registered address and postal address (if different).	We will liaise with you for this information and invite you to share it with us by email and other secure file transfer, such as Google.
Prospective Employees: Contact information and work history: name, email address, postal address, telephone number/s, previous employers, job titles and dates of employment.	If you are interested in a role here at Zinc Systems, we will invite you to send us your CV by email.
Suppliers: Contact information including your full name, Company name, email address, telephone number.	We will liaise with you for this information and invite you to share it with us by email and other secure file transfer, such as Google.
Payment information including card details, bank account numbers and other invoicing methods.	We will liaise with you for this information and invite you to share it with us by email and other secure file transfer, such as Google and enter this information into our CRM.
Profile information including preferences, and purchase history.	We will liaise with you for this information and invite you to share it with us by email and other secure file transfer, such as Google and enter this information into our CRM.
Data from third parties including credit history.	Information is provided by a third party credit scoring provider.
Usage data including unique identifiers such as cookies, web beacons and IP addresses.	This is collected through automated means when you interact with our website or social media pages (please refer to our Cookie Policy for more information on the unique identifiers we use).

6. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we will may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Administering our business.	Company/business and financial transaction information	Legal obligation to process with relevant government agencies
Supplying our services to our customers	Contact information for business interactions	Legitimate interests to support business to business interactions
Managing payments for our services	Contact and payment information as part of contracts	Legitimate interests to support business to business interactions
Tailoring our marketing related services for you	Usage data and unique identifiers	Consent via the cookiers banner on our website
Marketing our services to you	Contact and business information	Legitimate interests to support business to business interactions
Communicating with you.	Contact information for business interactions	Legitimate interests to support business to business interactions
Credit checks	Credit report including director information	Legitimate interests to support business to business interactions
Managing, supporting and safeguarding our employees and contractors	Please refer to employee data protection policy	Legitimate interest to manage employees and contractors
Security information analysis and sharing	Gather security information, carry out research and share with legitimate interest partners	Legitimate interest for the prevention and detection of crime

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We use the following automated systems for carrying out certain kinds of profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 11.

The following automated profiling may take place:
- We use tracking cookies and ‘web beacons’ (on our website) to build a profile based on the actions you took on and/or via our website and/or social media pages. We do not do this without your consent which is requested via the ‘cookie banner’ (on our website). The data gathered is used to provide you with information that is more relevant to you and more likely to be aligned with your requirements.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Prospective Customers: Contact information including your full name, Company name, email address, telephone number.	Twelve months. Before this, we will contact prospective clients to ask if they would like to maintain contact. If not, we will delete the data For as long as there’s the potential for us to work together, though we’ll endeavour to verify this at least every twelve months.
Customers: Contact information including your full name, Company name, email address, telephone number, registered address and postal address (if different).	For at least the duration of the contract, plus as long as there’s the potential for us to work together, though we’ll endeavour to verify this at least every twelve months.
Prospective Employees: Contact information and work history: name, email address, postal address, telephone number/s, previous employers, job titles and dates of employment.	If you are unsuccessful in an application to join us, we will delete your data immediately after the recruitment process. However we will seek your consent to retain your data for twelve if we have a mutual interest to work with each in the future.
Suppliers: Contact information including your full name, Company name, email address, telephone number.	For at least the duration of the contract, plus as long as there’s the potential for us to work together, though we’ll endeavour to verify this at least every twelve months.
Payment information including card details, bank account numbers and other invoicing methods.	For at least the duration of the contract.
Profile information including preferences, and purchase history.	For at least the duration of the contract.
Data from third parties including credit history.	For at least the duration of the contract.
Usage data including unique identifiers such as cookies, web beacons and IP addresses.	Various (please refer to our Cookie Policy for more information on the usage data and unique identifiers we use including their retention periods / lifespan / expiry).

8. How and Where Do You Store or Transfer My Personal Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

AND

We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

AND

We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
We have implemented and maintain appropriate technology solutions such as firewall/s, anti-virus software, SIEM and encryption to safeguard your data.
We have ISO27001:2013, Cyber Essentials and Secured By Design accreditation.

9. Do You Share My Personal Data?

Whilst we don’t share personal data with our infrastructure and support providers as such, it is possible that they could have some visibility of it whilst providing their services.

We contract with the following third party to supply services.

Recipient	Activity Carried Out	Location
VII Technologies Enterprises PVT Ltd	Software support and development	India.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 8.

We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Data Protection Manager:

Email address: DSARS@zinc.systems.

Telephone number: 01604 598989.

Postal Address: Data Protection Manager, Zinc Systems, 33 Bedford Road, Little Houghton NN7 1AB.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website at https://www.zinc.systems/privacy-notice/ and via our status page at https://status.zinc.systems/. This Privacy Notice was last updated on 21st April 2023.

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