ZGA DIGITAL WEBSITE PRIVACY POLICY
1. SCOPE AND CONTACT
This privacy policy explains how we use your personal data which we collect or obtain from our website.
Therefore, please read this privacy policy carefully before providing us with your personal data, or using our website or our services. Please contact us at [email protected] if you have any questions about our use of your personal data.
Please note that if you are a brand or influencer working with us, there are separate privacy policies available on our website which apply to the use of your personal data.
Controller of your personal data
A “controller” under data protection laws is the person that determines the purposes for which your personal data will be used and how it will be processed.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
Visitors to our website
You do not have to provide us with any personal information in order to browse our website. However, if you contact us using any of the contact details, or a contact form, set out on our website, then we collect the personal data which you provide to us, which will include:
- your name;
- your email address;
- date of birth;
- address/location;
- your telephone number; and
- any personal data which you choose to provide in your enquiry or other communication(s) with us.
Personal data which we and/or our service providers automatically collect when you use our website or services – certain data, including personal data, is collected when you visit our website or use our services. This includes:
- information collected when you access our website;
- your internet protocol (IP) address;
- your login data, browser type and version;
- time zone setting and location;
- browser plug-in types and versions;
- information about access to embedded social media content; and
- operating system and platform and other technology on the devices you are using.
Cookies
This site uses cookies — small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Square Space Analytics. This information lets us see how users are finding our webpages and online services and it tells us which pages and sites are visited the most often so we can make them more useful. This information in no way enables us to identify you personally.
As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. Further information about the cookies we use is set out in our cookie policy available on this website. We also suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.
3. HOW WILL YOUR PERSONAL INFORMATION BE USED?
In accordance with data protection legislation, we will only process your personal data where we have a lawful basis for doing so. These bases are: (i) where it is necessary for us to comply with a legal obligation that we are subject to; (ii) where it is in our (or a third party’s) legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms; or (iii) with your consent, where we request your consent.
Specifically, we’ve set out in the table below the purposes for which we process your personal data and the lawful basis on which we carry out such processing.
| Types of personal data | Purposes for processing | Legal basis for processing |
| Personal data which you provide to us, as described in section 2 above | To administrate our business and services, including customer service provision and communications to users of our website, including for the purpose of obtaining feedback on our services | Legitimate interests – being the provision, use and maintenance of a website to provide information about our services. |
| Data, including personal data, which we collect automatically, as described in section 2 above | To make our website/platform more intuitive and easy to use | Legitimate interests – being to monitor how our website is used to help us improve the layout and information available on our websites and provide a better service to our website users |
| Data, including personal data, which we collect automatically, as described in section 2 above | To protect the security and effective functioning of our website/platform and information technology systems | Legitimate interests – being to monitor how our website are used to detect and prevent fraud, other crimes and the misuse of our websites |
| Data, including personal data, which we collect automatically, as described in section 2 above | To use data analytics services (including Square Space Analytics) to improve our website, our services, marketing, customer relationships and experience | Legitimate interests – being the monitoring of traffic to our website, reviewing how clients use and what they think of our website, improving our website and identifying ways to grow our business |
| Personal data which you provide to us, as described in section 2 above | To market our products and services | Legitimate interests – being the promotion of our products and services |
| Personal data which you provide to us, as described in section 2 above Data, including personal data, which we collect automatically, as described in section 2 above | For legal or regulatory purposes | Compliance with a legal obligations to which we are subject |
4. HOW WILL YOUR PERSONAL INFORMATION BE SHARED?
Your personal data may be shared with:
- our service providers to the extent necessary to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified in section 3 above. These include: data hosting, infrastructure and IT service providers, for example, the providers of our client intake system, our finance systems and our customer relationship management databases; any third party consultants who provide us with support in respect of business analytics and marketing campaigns. We require such parties by contract to provide reasonable security for personal data and to use and process such personal data on our behalf only;
- professional services providers, such as our lawyers or accountants, in order for such persons to advise us on legal, accounting and financial matters; and
- any other legal entities which are, from time to time, part of the same corporate group as us.
5. TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE THE UK
We, and service providers processing personal data on our behalf, may transfer personal data to servers outside the UK including in the United States of America for storage purposes. However, this will not allow routine access to any personal data. These countries may not have equivalent data protection legislation to the UK. However, when we transfer your personal data in this way we will do so in compliance with applicable laws, including the UK GDPR, and endeavour to ensure that adequate safeguards are in place so that your personal data is treated in a way that is consistent with and which respects the UK laws on data protection, including via standard contractual clauses. If you require further information about our safeguard measures in place you can request it from [email protected]
6. LINKS
From time to time, our site may contain links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which we link from this site. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your personal data.
7. SECURITY
We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. However, the Internet is an open system and we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal data for improper purposes.
8. YOUR RIGHTS
You have certain rights in respect of your personal data under applicable data protection laws, as summarised below:
- right to be informed about how personal information is used – you have a right to be informed about how we will use and share your personal information. This explanation will be provided to you in a concise, transparent, intelligible and easily accessible format and will be written in clear and plain language;
- right to access personal information – you have a right to obtain confirmation of whether we are processing your personal information, access to your personal information and information regarding how your personal information is being used by us;
- right to have inaccurate personal information rectified – you have a right to have any inaccurate or incomplete personal information rectified. If we have disclosed the relevant personal information to any third parties, we will take reasonable steps to inform those third parties of the rectification where possible;
- right to have personal information erased in certain circumstances – you have a right to request that certain personal information held by us is erased. This is also known as the right to be forgotten. This is not a blanket right to require all personal information to be deleted. We will consider each request carefully in accordance with the requirements of any laws relating to the processing of your personal information;
- right to restrict processing of personal information in certain circumstances – you have a right to block the processing of your personal information in certain circumstances. This right arises if you are disputing the accuracy of personal information, if you have raised an objection to processing, if processing of personal information is unlawful and you oppose erasure and request restriction instead or if the personal information is no longer required by us but you require the personal information to be retained to establish, exercise or defend a legal claim;
- right to data portability – in certain circumstances you can request to receive a copy of your personal information in a commonly used electronic format. This right only applies to personal information that you have provided to us (for example by completing a form or providing information through a website). Information about you which has been gathered by monitoring your behaviour will also be subject to the right to data portability. The right to data portability only applies if the processing is based on your consent or if the personal information must be processed for the performance of a contract and the processing is carried out by automated means (i.e. electronically);
- right to object to processing of personal information in certain circumstances, including where personal information is used for marketing purposes – you have a right to object to processing being carried out by us if (a) we are processing personal information based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal information for direct marketing purposes, or (c) if information is being processed for scientific or historical research or statistical purposes. You will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information; and
- right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect – you have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.
You may exercise any of your rights at any using the contact details set out in Section 9 below. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you do choose to withdraw your consent, we may have to cease providing services to you which require the processing of personal data for which we require your consent.
If you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.
If you are resident in the UK, you can find the contact details for the UK data protection regulator here: https://ico.org.uk/global/contact-us/
9. CONTACTING US
Please contact us in the first instance if you have any questions or complaints about our use of your personal data. We take your privacy very seriously and will do everything we can to address your questions and concerns.
You can contact us at: [email protected]
10. RETENTION
We will only retain your personal data for as long as necessary for the purposes set out in this privacy policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. Accordingly, we use the following criteria to determine the period for which we retain your personal data:
- the period for which the personal data is required for the applicable purposes set out in this privacy policy; or
- any statutory limitation period relevant to a claim for which the personal data; or
- any statutory or regulatory retention period applicable to the personal data.
11. CHANGES TO OUR PRIVACY POLICY
If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what personal information we collect, how we use it and under what circumstances, if any, we will share it with other parties.