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PRIVACY NOTICE

 

Effective date: 04/03/2021

 

1. Introduction

  

Synthio Limited, a limited liability company registered in Ireland with the registration number 569132, which trades as "Zenio Partners" (“us”, “we”, or “our”) operates www.zeniopartners.com (hereinafter referred to as “Website”).

 

Our Privacy Notice applies to information we process in connection with your visit to www.zeniopartners.com, use of our services and/or interaction with us in the course of business and explains how we collect, safeguard and disclose information that results from your use of our Website and our provision of services to you or your employer.

 

2. Information Collection and Use

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

(a) Identity Data includes first name, maiden name, last name, username or similar identifier, title/position, date of birth and gender.

 

(b) Contact Data includes billing address, business address, business name, email address and telephone numbers.

 

(c) Technical Data includes internet protocol (IP) address, device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

 

(d) Profile Data includes your LinkedIn profile username, your interests, preferences, feedback and survey responses.

 

(e) Usage Data includes information about how you use our Website.

 

(f) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

 

3. How is your personal data collected?

 

We use different methods to collect data from and about you including through:

 

(a) Direct interactions. You may give us your Identity and Contact Data filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

 

  • use our services on your own behalf or on behalf of your employer;

  • subscribe to our publications;

  • request marketing to be sent to you;

  • enter a survey;

  • apply for a job in our "Careers" section;

  • give us some feedback; or

  • submit a query.

 

(b) Third parties or publicly available sources. We may receive personal data about you from various third parties, including Technical Data from analytics providers/advertising networks and search information providers such as Google.

 

4. How we use your personal data

 

(a) Lawful Basis: We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances where:

 

  • we need to perform the contract we are about to enter into or have entered into with you;

  • it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

  • where we need to comply with a legal or regulatory obligation.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at team@zeniopartners.com.

 

(b) Purposes for which we will use your personal data

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data (i) for more than one lawful ground depending on the specific purpose for which we are using your data and (ii) without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. Please contact us at team@zeniopartners.com if you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose or you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity 1

To manage our relationship with you which will include:

(a)   providing information you request via email, phone calls, WhatsApp or SMS/Text message

(c)   notifying you about changes to our terms or Privacy Notice

(d)  asking you to complete a market research survey

(e)  other activities necessary for the maintenance of our relationship with you

Type of data

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Marketing and Communications

Lawful basis for processing including basis of legitimate interest

(a) performance of a contract with you

(b)   necessary to comply with a legal obligation

(c) necessary for our legitimate interests (for market research to improve our services and identify or validate new training opportunities/lobbying purposes, to keep our records updated and to study how  our services are used and develop our offerings)

Purpose/Activity 2

To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

Type of data

(a)   Identity

(b)   Contact

(c)   Technical

Lawful basis for processing including basis of legitimate interest

(a) necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b)   necessary to comply with a legal obligation

Purpose/Activity 3

To deliver relevant content and advertisements to you on our Website, third party websites and social media channels, and measure or understand the effectiveness of the advertising we serve to you

Type of data

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)    Technical

Lawful basis for processing including basis of legitimate interest

necessary for our legitimate interests (to study how users use our and services, to develop them, to grow our business and to inform our marketing strategy)

 

Purpose/Activity 4

Marketing to you about our activities

Type of data

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)    Technical

Lawful basis for processing including basis of legitimate interest

(a) necessary for our legitimate interests (in promoting our activities, supporting our marketing strategy and sending you marketing materials, noting that you have the right to object to such marketing communications at any time).

(b) you have provided consent (which may be withdrawn at any time)

Purpose/Activity 5

To use data analytics to improve our Website and services, offers, marketing, customer relationships and experiences

Type of data

(a)   Technical

(b)   Usage

Lawful basis for processing including basis of legitimate interest

necessary for our legitimate interests (to define types of customer for our service offerings, to keep our Website and services up-to-date and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity 6

To make suggestions and recommendations to you about offers that may be of interest to you

Type of data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Lawful basis for processing including basis of legitimate interest

necessary for our legitimate interests (to develop our  services, grow our business)

Purpose/Activity 7

To comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or in response to a physical threat to you or others, to protect property or defend or assert legal rights.

Type of data

(a)   Identity

(b)   Contact

(c)   Profile

(d)   Usage

(e)   Marketing and Communications

(f)    Technical

Lawful basis for processing including basis of legitimate interest

(a) necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) necessary to comply with a legal obligation

 

(a) Legal Compulsion

 

In the event that we are legally compelled to disclose your personally identifiable information to a third party, we will attempt to notify you unless doing so would violate the law, court order or government instruction.

(b) General marketing

 

We do not sell, rent or lease our customer lists to third parties.  We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

(c) Promotional offers from us

 

  1. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

  2. You will receive marketing communications from us if you have requested information from us, received a service from us, or if you provided us with your details have not opted out of receiving that marketing.

 

(d) Third-party marketing

 

We will get your express opt-in consent before we share your personal data with any company outside Zenio Partners for marketing purposes.

 

(e) Internet based advertising

 

We use LinkedIn, Google Search & Display, Facebook and Twitter advertising services and as such there are tracking codes installed on our Website so that we can manage the effectiveness of these campaigns.  We do not store any personal data within this type of tracking.

(f) Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at team@zeniopartners.com at any time.

 

(g) Analytics

 

We may use Google Analytics to monitor and analyze the use of our Website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

 

(h) Tracking Cookies Data

 

We use cookies and similar tracking technologies to track the activity on our Website and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Website.

 

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Website.

  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

  • Security Cookies: We use Security Cookies for security purposes. Advertising

  • Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

 

5. Retention of Data

 

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Notice including to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We keep basic information about our customers for six years after they cease being customers for tax and other legal purposes.

 

 

6. Transfer of Data

 

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of the European Economic Area ("") where the data protection laws may differ from those of your jurisdiction. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

 

  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7. Disclosure of Data

 

We may disclose personal information that we collect, or you provide with the parties set out below for the purposes :

 

  • External Third Parties as set out in the Glossary;

 

  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; alternatively, we may seek to acquire other businesses or merge with them; if a change happens to our business, then the new owners or newly acquired businesses may use your personal data in the same way as set out in this Privacy Notice.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

8. Security of Data

 

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

 

9. Links to Other Sites

 

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy notices of every site you visit.

 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

10. Children's Privacy

 

Our Website is not intended for use by children under the age of 18 (“Child” or “Children”).

 

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

 

11. Changes to This Privacy Notice

 

We may update our Privacy Notice from time to time and when we do we will post a prominent notice on this page together with the updated Privacy Notice with the new “effective date” at the top of this Privacy Notice. You are advised to review this Privacy Notice periodically for any changes. Save in the case of material changes, changes to this Privacy Notice are effective when they are posted on this page.

 

Where we make material changes to how we process your Personal Data and we have your email address, we will let you know via email, prior to the change becoming effective.
 

12. Glossary

 

Terms and Definitions

 

Controller

means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Notice, we are a Data Controller of your data

External Third Parties

  • service providers who provide IT, system administration services, cloud storage and other services.;

 

  • professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services; and

 

  • the Revenue Commissioners, regulators and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.

Lawful Basis

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best offering and the best and most secure experience; we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at team@zeniopartners.com.

 

  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personal Data

data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

 

Processor

any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

 

 

 

13. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

 

In certain circumstances, you have the right to:

 

  • Request access: to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

  • Request correction: of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

  • Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

  • Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have a compelling legitimate ground to process your information which overrides your rights and freedoms.

 

  • Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

  • Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

  • Withdraw consent at any time: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain offerings to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of these rights, please email us at team@zeniopartners.com.Please note that we may (i) ask you to verify your identity before responding to such requests.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.

 

14. Contact Us

 

If you require any further information or have any questions about this Privacy Notice, please contact us:

 

By email: team@zeniopartners.com.

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