Zerocode Privacy Policy


This privacy policy applies between you, the User of Zerocode Services and Zerocode Ltd. (“Zerocode”), the owner and provider of Zerocode Services. Zerocode takes the privacy of your information very seriously.

This privacy policy explains how Zerocode processes and protects information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of all the products and services offered by Zerocode.

For the purposes of this policy, Zerocode defines the term “User” as an entity who registers for our Services through our website and the term “Visitor” as an individual that visits our website (e.g. https://zerocode.io).

This privacy policy should be read alongside, and in addition to, our Terms & Conditions.

1. Definitions and Interpretation

In this privacy policy, the following definitions are used:

Data

collectively all information that you submit to Zerocode Ltd. via the Website and our Proprietary Software sold through the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws

any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR

the General Data Protection Regulation (EU) 2016/679;

Zerocode Ltd.,
we or us

Zerocode Ltd., a company incorporated in England and Wales with registered number 12013734 whose registered office is at The Long Lodge 265-269 Kingston Road, Wimbledon, London, England, SW19 3NW;

Zerocode Services

Any service provided by Zerocode including the website (www.zerocode.io) and proprietary software and Consultancy Services sold by Zerocode Ltd.

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you

any third party that accesses Zerocode Services and is not either (i) employed by Zerocode Ltd. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Zerocode Ltd. and accessing the Zerocode Services in connection with the provision of such services; and

Website

the website that you are currently using, www.zerocode.io, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

 

In this privacy policy, unless the context requires a different interpretation:

    1. the singular includes the plural and vice versa;
    2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
    3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
    4. "including" is understood to mean "including without limitation";
    5. reference to any statutory provision includes any modification or amendment of it;
    6. the headings and sub-headings do not form part of this privacy policy.

2. Scope of this Privacy Policy

  1. This privacy policy applies only to the actions of Zerocode Ltd. and Users with respect to Zerocode Services. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.
  2. For purposes of the applicable Data Protection Laws, Zerocode Ltd. is the "data controller". This means that Zerocode Ltd. determines the purposes for which, and the manner in which, your Data is processed.

3. Collection and use

  1. The following sections cover the specifics of Website Visitors and Users from which data is collected.

4. Website Visitors

  1. By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.

4.1 Data collected

  1. We may collect the following Data, which includes personal Data, from you:
    1. name;
    2. job title;
    3. profession;
    4. contact Information such as email addresses and telephone numbers;
    5. IP address (automatically collected);
    6. web browser type and version (automatically collected);
    7. operating system (automatically collected);
    8. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

4.2 How we collect Data

  1. We collect Data in the following ways:
    • data is given to us by you; and
    • data is collected automatically.

4.3 Data that is given to us by you

  1. Zerocode Ltd. will collect your Data in a number of ways, for example:
      1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
      2. when you register with us and set up an account to receive our products/services;
      3. when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
      4. when you elect to receive marketing communications from us;
      5. when you use our services;

in each case, in accordance with this privacy policy.

4.4 Data that is collected automatically

  1. To the extent that you access the Website, we will collect your Data automatically, for example:
      1. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
      2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

4.4.1 Cookies

      1. This Website may place and access certain Cookies on your computer. Zerocode Ltd. uses Cookies to improve your experience of using the Website. Zerocode Ltd. has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
      2. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
      3. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Zerocode Ltd. to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
      4. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
      5. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
      6. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
      7. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

4.5 Purpose of processing personal data

Zerocode uses the collected data to communicate with Visitors, to customise content for Visitors, and to improve its website by analysing how Visitors navigate its website.

4.6 Our use of Data

  1. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
      1. internal record keeping;
      2. improvement of our products / services;
      3. transmission by email of marketing materials that may be of interest to you;
      4. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

in each case, in accordance with this privacy policy.

  1. We do not sell, trade, or rent your personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes.
  2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
  3. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
      1. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt-out.
      2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
      3. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
      4. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.7 Data Sharing

  1. We may share your Data with the following groups of people for the following reasons:
      1. any of our group companies or affiliates - to deliver services or provide information about services;
      2. our employees, agents and/or professional advisors - to deliver services or obtain advice from professional advisers;
      3. third party service providers who provide services to us which require the processing of personal data - to help third party service providers in receipt of any shared data to perform functions on our behalf;
      4. third party payment providers who process payments made over the Website - to enable third party payment providers to process user payments and refunds;
      5. relevant authorities - to facilitate the detection of crime;

in each case, in accordance with this Privacy Policy.

4.8 Links to other sites

  1. Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. Zerocode is not responsible for the content or privacy policy of these other sites.

5. Users

  1. In order to provide services to its Users, Zerocode collects certain types of data from them. This section will describe how these two types of data are collected and used by Zerocode. Data entered or transferred into Zerocode by Users remains the property of the User and may not be shared with a third party by Zerocode without express consent from the User.

5.1 Collection of User data from our customers

  1. Information in this category includes the information you provide when registering to use our services, and for further usage of our services. This data is primarily stored within Zerocode and a part of it may also be stored in third party services.

5.2 Personal information stored by Zerocode

  1. First name, last name, email, company name, phone number
  2. Stripe customer and subscription unique identifiers
  3. IP addresses for managing licensing

5.3 Personal information stored in third party services

  1. Name and email (through Hubspot)
  2. Company name (through Hubspot)
  3. Links to social media profiles (through Hubspot)
  4. Credit card information (securely stored within Stripe)
  5. Website usage (through Google Analytics)
  6. Geographic location (through Google Analytics)
  7. IP addresses for Licensing (through Crypltex)
  8. Username of the device (through Zerocode - hashed using SHA256)

 

6. GDPR

  1. The European Parliament adopted the GDPR in April 2016, replacing an outdated data protection directive from 1995. It carries provisions that require businesses to protect the personal data and privacy of EU citizens for transactions that occur within EU member states. We will apply the GDPR to all the users whose personal data is either stored within Zerocode or who use our services, whether inside or outside of the EU.
  2. Zerocode processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR.

6.1 Controller

  1. In the GDPR “controller’ means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union/Member State law.
  2. For user data, as outlined in the section 5, Zerocode will be the data controller.

6.2 Processor

  1. The processor is the entity which processes personal data on behalf of the controller under the controller’s instructions.
  2. Zerocode are a data processor.

6.3 Lawful basis of processing

  1. If you are our User, we process your Personal Data based on your consent, and based on the need to perform the obligations of our contract with you. We collect and use Personal Data for the purposes of providing the Services to our Users at their instruction, processing Personal Data on behalf of Users, improving the Services, and conducting related tasks for legitimate business purposes.

6.4 Data Protection Officer

  1. Zerocode has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This “Data Protection Officer” can be contacted through email at legal@zerocode.io.

7. Data security

  1. Zerocode is committed to ensuring that your privacy and the data you share with us is protected. We use best industrial practices to secure and protect the important business data you store within Zerocode.
  2. All information is stored securely and is accessed by authorized personnel only. Zerocode implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
  3. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us.
  4. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

8. Retention and deletion

  1. Zerocode will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. When a user's account is terminated, all the related Personal Data stored within Zerocode will be deleted, as required by applicable law. For the user data, collected by you (our customer), with an active account, you will have the responsibility to delete the data when required.  Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

9. Acceptance of these conditions

  1. We assume that all visitors of our website, and users of Zerocode services have carefully read this document and agree to its contents. If someone does not agree with this Privacy Policy, they should refrain from using our website and services. We reserve the right to change our Privacy Policy as necessity dictates. Continued use of Zerocode website and services after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This privacy policy is an integral part of Zerocode’s Terms of Service.

10. Disclosure of personal information

  1. We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Zerocode or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

11. Rights of access, rectification and erasure

  1. You have the following rights in relation to your Data:
    1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase - the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
    5. Right to data portability - the right to request that we move, copy or transfer your Data.
    6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
  2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us.
  3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
  4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
  5. Although Zerocode makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Zerocode is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Zerocode determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Zerocode will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

12. Opt-Out (Right To Restrict Processing)

12.1 General

  1. You have the right to opt-out of certain uses and disclosures of your personal information. Where you have consented to Zerocode's processing of your personal information, you may withdraw that consent at any time and opt-out to further processing by contacting us at legal@zerocode.io. Even if you opt-out, we may still collect and use non-personal information regarding your activities on our site.

12.2 Email communications

  1. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Zerocode and our services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).
  2. WE MAINTAIN “DO-NOT-MAIL” LISTS AS MANDATED BY LAW. WE PROCESS REQUESTS TO BE PLACED ON DO-NOT-MAIL AND DO-NOT-CONTACT LISTS WITHIN 60 DAYS AFTER RECEIPT, OR SUCH SHORTER TIME AS MAY BE REQUIRED BY LAW.

13. Onward transfer - Zerocode may disclose your information

13.1 Information we share

  1. We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.
    1. We use vendors and service providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust personal information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site.
    2. Privacy Shield. With respect to onward transfers to Agents under Privacy Shield, Privacy Shield requires that Zerocode remain liable should its Agents process personal information in a manner inconsistent with the Privacy Shield Principles.
    3. Disclosures to protect us or others (e.g., as Required by law and similar disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Zerocode policies or contracts; (v) to collect amounts owed to Zerocode; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
    4. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
    5. Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Zerocode will endeavour to direct the transferee to use personal information in a manner that is consistent with the Privacy Policy in effect at the time such personal information was collected.

14. Changes to this privacy policy

    1. Zerocode Ltd. reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

      You may contact Zerocode Ltd. here.
    2. Changes of business ownership and control
    1. Zerocode Ltd. may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Zerocode Ltd.. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
    2. We may also disclose Data to a prospective purchaser of our business or any part of it.
    3. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

    15. General Terms

     

    You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
    1. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
    2. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
    3. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

    16. For further information

    1. If you have any further questions regarding the data Zerocode collects, or how we use it, then please feel free to contact us by email at: legal@zerocode.io

    Last updated 26-07-2020