Privacy Policy

27/05/2011

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Zen Internet Limited of Sandbrook Park, Sandbrook Way, Rochdale OL11 1RY ("Zen").
1 INFORMATION WE MAY COLLECT FROM YOU
1. We may collect and process the following data about you:
  - information that you provide by filling in forms on our site zen.co.uk (our site). This includes information provided at the time of registering to use certain elements of our site, subscribing to our services, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by Zen, and when you report a problem with our site;
  - if you contact us, we may keep a record of that correspondence;
  - we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
  - details of transactions you carry out through our site or via other means (eg telephone orders) and of the fulfilment of your orders;
  - you can access the site home page and browse the site without disclosing personal information. We collect standard Internet log information and details of visitor behaviour patterns to help us identify things such as the number of visitors to the various parts of our site. We collect this information in a way which does not identify anyone (please see the following section for more details); and
  - communication and usage data, whether this is required for our own billing purposes or otherwise and the resources that you access. We do not collect the content of emails that you have sent or received or keep a record of individual web pages that you have visited.
2 IP ADDRESSES AND COOKIES
1. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
  - to conduct transactions on our site;
  - to estimate our audience size and usage pattern;
  - to store information about your preferences, and so allow us to customise our site according to your individual interests;
  - to speed up your searches; and
  - to recognise you when you return to our site.
2. We are aware of the forthcoming changes to the Privacy and Electronic Communications Regulations 2011 and are working to be fully compliant with these changes as soon as we can. We are following the ICO’s advice on the changes and how they will be enforced and we will update this section to relect this. Our intention is to set out in more detail about what cookies we currently use, their purpose and how you can manage and/or disable them.
3. In the meantime, we have set out below how we currently use cookies on our site.
4. One of the cookies we use is essential for parts of the site to operate and has already been set. This is called an ASP.NET Session cookie and it is essential to the functionality of our site. This cookie is deleted when you leave our site. You can read more about this type of cookie at http://support.microsoft.com/kb/899918.
5. We use Google Analytics, a web analytics service provided by Google, Inc. This analytical tool uses cookies to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of our site (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of our site and to compile statistical reports on website activity for Zen.
6. The information generated by the cookie about your use of our site will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our site, compiling reports on website activity and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google undertakes not to associate your IP address with any other data held by Google. Google Inc are also members of the US Safe Harbor Scheme. Companies that sign up to this scheme are deemed to provide adequate protection for personal data which has been transmitted to them from Europe.
7. To find out more about cookies, including how to control and delete them, visit http://www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout or http://www.google.co.uk/intl/en/analytics/privacyoverview.html to find out more about Google Analytics generally. If you have Adobe Flash installed on your computer and you use our site’s audio or video players, Google Analytics will try to store some additional data on your computer. This data is known as a Flash cookie. This helps us to analyse the popularity of our media files. Adobe’s website offers tools to control these cookies on your computer at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
3 WHERE WE STORE YOUR PERSONAL DATA
1. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
2. In addition, if you place your personal information on publically available parts of our site, this will be accessible to people in countries outside of the EEA. Such countries may not have data protection laws as comprehensive as those that exist within the EEA.
3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
4. Unfortunately, the transmission of information via the Internet is not completely secure. Athough we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
4 USES MADE OF THE INFORMATION
1. We use information held about you in the following ways:
  - to provide you with information, products or services that you request from us or which we feel may interest you (where you have consented to be contacted for such purposes);
  - to carry out our obligations arising from any contracts entered into between you and us;
  - to allow you to participate in any interactive features of our services, if you choose to do so;
  - to ensure that content from our site is presented in the most effective manner for you and for your computer; and
  - to notify you about changes to our service.
2. We may also use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by post or telephone.
3. If you are an existing customer, we will only contact you by electronic means (email or SMS) with information about goods and services similar to those which were the subject of a previous sale to you.
4. If you are not a customer we will contact you by electronic means only if you have consented to this.
5. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data or contact us at dataprotection@zeninternet.co.uk.
5 DISCLOSURE OF YOUR INFORMATION
1. We may disclose your personal information to third parties:
  - in order to fulfil your order for goods or services;
  - to enable us to provide maintenance, engineering or troubleshooting services to you in connection with goods or services supplied to you;
  - in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  - if Zen or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  - if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or
  - to protect the rights, property, or safety of Zen, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6 YOUR RIGHTS
1. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also change your preferences at any time on our Customer Portal at https://portal.zen.co.uk/ or via email to dataprotetction@zeninternet.co.uk.
2. Our site may, from time to time, contain links to and from the websites of our partner networks, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7 ACCESS TO INFORMATION
1. The Act gives you the right to access information held about you. You can find out what information we hold about you by making a Subject Access Request under the Act. If we hold personal information about you we will give you a description of it, tell you why we are holding it and let you have a copy of it.
8 UPDATING OR AMENDING INFORMATION
1. If any of the personal information that we hold about you is incorrect or needs updating, or if you want us to delete any personal information, please contact us. We may request that you provide further information and identification to enable us to comply with this request.
9 CHANGES TO OUR PRIVACY POLICY
1. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. This policy was last updated on 27 May 2011.
10 CONTACT
1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Compliance Manager at Zen Internet Limited, Sandbrook Park, Sandbrook Way, Rochdale OL11 1RY or at dataprotection@zeninternet.co.uk.

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