Privacy policy & cookies

Introduction

1. Zones are committed to safeguarding the privacy of its website visitors and service users
2. This policy applies where Zones act as a data controller with respect to the personal data of its customers, website visitors and service users; in other works, where we determine the purposes and means of the processing of that personal data.
3. By using our website and agreeing to this policy, you consent to our user of cookies in accordance with the terms of this policy.
4. In this Policy, “we”, “us” and “our” refer to Zones (UK) Ltd. For more information about us, see section 13.

How we use your personal data

1. In this Section 2 we have set out:
   1. the general categories of personal data that we may process;
   2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
   3. the purposes for which we may process personal data; and
   4. the legal bases of the processing.
2. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3. We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and, OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4. We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, telephone number, job title and email address. The profile data may be processed for the purposes of employment details. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and, the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
5. We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, telephone number, job title and email address. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
6. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
7. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. 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 and our legitimate interests, namely our interest in the proper administration of our website and business.
8. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
9. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
10. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
11. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
12. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
13. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. We may disclose usage data, account data, profile data, service data, enquiry data, transaction data, notification data or correspondence data to our suppliers or subcontractors insofar as reasonably necessary for the purpose of providing goods and services.
4. In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data

1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
2. We and our other group companies have offices and facilities in countries, as listed in the addendum. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from The European Commission website – https://ec.europa.eu/
3. The hosting facilities for our website are situated in The United Kingdom. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of the UK.

Retaining and deleting personal data

1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data using the following criteria:
   How long is the personal information needed to provide our Services? This includes such things as maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. This is the general rule that establishes the baseline for most of our data retention periods.
   Is the personal information sensitive? If so, a shortened retention time is generally appropriate.
   Have you provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
4. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:Is there a legal, contractual, or similar obligation to retain your personal information? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or personal information retained for the purposes of litigation.After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner according to our data retention and deletion policies.
5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We may notify you of changes to this policy by email or through the private messaging system on our website.

Your rights

1. You may instruct us to provide you with any personal information we hold about you; provision of such information may be subject to:
   1. a nominal payment of a fee (currently fixed at GBP 10); and
   2. the supply of appropriate evidence of your identity.
2. We may withhold personal information that you request to the extent permitted by law.
3. You may instruct us at any time not to process your personal information for marketing purposes.
4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
   You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8. To the extent that the legal basis for our processing of your personal data is:
   1. consent; or
   2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

   and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11. You may exercise any of your rights in relation to your personal data by written notice to us via email.

About cookies

1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use (set by https://uk.zones.com/ and, or https://shop.ukzones.com/)

1. We use cookies for the following purposes:
   Name: acceptCookies
   Content: None
   Used for: Remembering if a user has accepted the use of Analytics cookies; if so, do not display the cookies notification bar on the website
   Expires: 1 year
2. Additionally we may use cookies to provide you with e-commerce services:

Cookies used by our service providers

1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are:
   Name: _utma
   Content: randomly generated number
   Used for: identifying unique visitors
   Expires: 2 years
   Name: _utmb and _utmc
   Content: randomly generated number
   Used for: identifying the current session
   Expires: 30 minutes
   Name: _utmz
   Typical content: randomly generated number + info on how the site was reached
   Used for: tracking how visitors came to our website
   Expires: 6 months
   If you wish for your visit to our site to NOT be tracked – thus removing the Analytics cookies – please visit: https://www.techadvisor.co.uk/how-to/internet/how-delete-cookies-browsing-history-3218163/.

Managing cookies

1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
   1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
   2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
   3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
   4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
   5. https://support.apple.com/kb/PH21411 (Safari); and
   6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
2. Blocking all cookies will have a negative impact upon the usability of many websites.
3. If you block cookies, you will not be able to use all the features on our website.

Our details

1. This website is owned and operated by Zones (UK) Ltd.
2. We are registered in England and Wales under registration number 02823778, and our registered office is at St Clements House, 27 Clements Ln, London EC4N 7AE.
3. Our principal place of business is at St Clements House, 27 Clements Ln, London EC4N 7AE.
4. You can contact us:
   by post, to the postal address given above;
   using our website contact form at https://uk.zones.com/;
   by telephone, on the contact number published on our website from time to time; or
   by email, using the email address published on our website from time to time.

Our details

1. Our data protection officer’s contact details are: dpo@ukzones.com

Credit

1. This document was created using a template from SEQ Legal (https://seqlegal.com).