Owner and Data Controller
ZuLogic Limited, Three Trees, The Street, Ulcombe, Kent ME17 1DX
Owner contact email: support@zulogic.co.uk
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; last name; phone number; company name; email address.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Contacting the User, Content commenting, Managing contacts and sending messages, Displaying content from external platforms and Handling payments.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: company name; email address; first name; last name; phone number.
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: email address.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Website.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (this Website)
This Website has its own internal content comment system.
Personal Data processed: first name; last name.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Handling payments
Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
dotmailer (dotmailer Limited)
dotmailer is an email address management and message sending service provided by dotmailer Limited.
Personal Data processed: Cookies; email address.
Place of processing: United Kingdom – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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iCloudHosting
As to that of the Client itself and its representatives, the Supplier
shall act in accordance with industry practice in protecting that
personal data, and shall not sell or otherwise transfer it to third
parties for marketing activities in any circumstance. On occasion,
the Supplier may need to provide the Client’s name and delivery
address to third parties that the Supplier may use for the
purposes of delivering specific services to the Client or its
proposed successors. The Supplier shall not provide any of the
Client’s personal information to other companies or individuals
for marketing purposes without the Client’s permission. The
Supplier shall be entitled to use the personal data of the Client in
the due performance of the Services, this Agreement and (unless
opted out in writing from time to time) for communication to the
Client of the Supplier’s own marketing information.
As to personal data supplied by or through the Client in the
course of its business (including that of its customers and end
users,) the remaining part of this section shall apply:
1.1 Both parties will comply with their respective
obligations under the applicable requirements of the Data
Protection Laws.
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1.2 The parties acknowledge that for the purposes of the
Data Protection Laws and so far as this relationship under this
Agreement is concerned, the Client is the data controller and The
Supplier is the data processor (where Data Controller and Data
Processor have the meanings as defined in the Data Protection
Laws). The following sets out the scope, nature and purpose of
processing by the Supplier, the duration of the processing and the
types of personal data (as defined in the Data Protection Laws,
Personal Data) and categories of Data Subject:
(a) Processing by the Supplier: The provision of data
hosting services for the Client and indirectly its customers.
(b) Types of personal data: Each of the Client or its
customers decide individually which users’ data is processed by
configuration of data specific fields in the provided software or
interface. Often, these are: first name(s), surname, department /
organization, telephone number, fax number, e-mail address, IP
address, address, skype number, internal employee number,
payment details, other contact detail, location and personal data
within the content of material transmitted and/or stored. Special
or sensitive personal data is usually not requested or collected
unless incidentally within content itself or unless the Client
notifies the Supplier of any in writing.
(c) Categories of data subject:
(i) Each of the Client or its customers decide
individually the category of data subjects. Usually, these are:
employees of or workers within the organisation as well as
employees/workers of their partners and customers.
(ii) To submit ideas or create other content,
users need to register accounts. In these accounts, personal data
is managed by the user (in particular, registration, correction,
deletion).
in each case subject to any agreed written variation or addition
between the Client and the Supplier.
1.3 The Client declares and acknowledges that the
Supplier has no control, involvement, role or responsibility as to
the type or use of data put by the Client itself or third parties
generally nor, without limitation, the Client’s servants, agents,
customers or suppliers or end-users of the Client’s services or
those of the Client’s customers and the Supplier merely provides
an IT repository for data with a specified conduit for its
movement to and from the Client or third party infrastructure.
The Supplier’s processing does not include the manipulation,
selection, ordering, searching or monitoring of such Personal Data
other than in a generic sense of storage in the scope of the
Services. The Client is responsible for the cleansing, updating,
timely deletion and maintenance of Personal Data.
1.4 The Client will ensure that it has all necessary
appropriate consents and notices in place to enable lawful
transmission of the Personal Data to the Supplier and its
processing in accordance with this Agreement for the duration
and purposes of this Agreement.
1.5 Without prejudice to the generality of clause 1.1, the
Supplier shall, in relation to any Personal Data processed in
connection with the performance by the Supplier of its
obligations under this Agreement:
(a) process that Personal Data only in accordance with the
performance of the Services and otherwise either required under
this Agreement (this Agreement being agreed to constitute
written instructions from the Client for processing of Personal
Data) or by variation of Services agreed with the Supplier; or
(b) process that Personal Data if required by the laws of
any member of the European Union or by the laws of the
European Union applicable to the Supplier to process Personal
Data (Applicable Laws). Where the Supplier is relying on laws of a
member of the European Union or European Union law as the
basis for processing Personal Data outside of pre-agreed
processing, the Supplier shall promptly notify the Client of this
before performing the processing required by the Applicable Laws
unless those Applicable Laws prohibit the Supplier from so
notifying the Client;
(c) ensure that it has in place appropriate, industrystandard
for England, technical and organisational measures to
protect against unauthorised or unlawful processing of that
Personal Data and against accidental loss or destruction of, or
damage to, those Personal Data, having regard to the state of
technological development and the cost of implementing any
measures;
(d) ensure that all personnel who have access to and/or
process those Personal Data are obliged not to permit disclosure
of the Personal Data except as required by law or for the
purposes of this Agreement; and
(e) not transfer any of those Personal Data outside of the
European Economic Area (other than the Client’s transmission
and receipt of data over the Internet and the use of similar
networks that may involve part of the network being located
outside the European Economic Area and/or the UK), unless the
prior written consent of the Client has been obtained;
(f) assist the Client, at the Client's cost using the
Supplier’s then current standard time rates, in responding to any
request from a Data Subject and in ensuring compliance with its
obligations under the Data Protection Laws with respect to
security, breach notifications, impact assessments and
consultations with supervisory authorities or regulators;
(g) notify the Client without undue delay on becoming
aware of a material Personal Data breach committed by the
Supplier, its servants or agents and take reasonable steps to
prevent further disclosure or breach and mitigate the potential
adverse effects on affected data subjects in cooperation with the
Client;
(h) at the written direction of the Client, delete or return
to the Client or allow the Client to retrieve from dedicated
equipment the Personal Data and copies thereof on termination
of the Agreement unless required by Applicable Law to store the
Personal Data;
(i) maintain appropriate records and information to
demonstrate its compliance with this clause 1;
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(j) in accordance with Data Protection Laws, make
available to the Client such information as is reasonably necessary
to demonstrate the Supplier’s compliance with its obligations
under Article 28 of the GDPR (and under any Data Protection
Laws equivalent to that Article 28), and allow for and contribute
to audits, including inspections, by the Client’s professional
appointee for this purpose, subject to the Client:
(1) giving the Supplier reasonable prior notice
of such information request, audit and/or inspection being
required by the Client;
(2) ensuring that all information obtained or
generated by the Client or its auditor(s) in connection with such
information requests, inspections and audits is kept strictly
confidential (save for disclosure to the supervisory authority
under Data Protection Laws or as otherwise required by
Applicable Laws);
(iii) ensuring that such audit or inspection is undertaken
during normal business hours, with minimal disruption to the
Supplier’s business, any sub-processors’ business and the
business of other customers of the Supplier; and
(k) paying the Supplier’s costs using the then current
standard time rates of the Supplier for assisting with the provision
of information and allowing for and contributing to inspections
and audits.
1.6 The Client consents to the Supplier appointing thirdparty
processor of Personal Data under this Agreement. The
Supplier confirms that it has entered or (as the case may be) will
enter with the third-party processor into a written agreement
substantially on that third party's standard terms of business (to
be supplied to the Client if requested other than commercially
sensitive information). The Supplier may, at any time on not less
than 30 days’ notice, revise this clause 1 by replacing it with any
applicable controller to processor standard clauses or similar
terms forming part of an applicable certification scheme (which
shall apply when replaced by addition of an attachment or
schedule to this Agreement). In addition and notwithstanding any
other provisions of this clause, the approval requirements for
subcontracting shall not apply in cases where the Supplier
subcontracts ancillary deliverables to third parties; such including,
the provision of external contractors, data back-up and disaster
recovery, telecoms providers, third party hosting providers, third
party colocation providers, mail, shipping and receiving services,
and maintenance services. The Supplier shall conclude, with such
third parties, any agreement reasonably necessary for the
adequate protection of Personal Data.
1.7 The Supplier shall nominate a point of contact for all
issues related to data privacy and protection within the scope of
the Agreement and pending notification otherwise this will be the
Managing Director.
1.8 The Client shall immediately confirm oral instructions
(at the minimum in text form) relevant to Personal Data.
1.9 If the Supplier informs the Client that it considers that
an instruction violates Data Protection Laws then it shall be
entitled to suspend the execution of the relevant instructions
until the Client satisfactorily confirms compliance or changes
them.
1.10 The Client shall, without undue delay and in a
comprehensive fashion, inform the Supplier of any defect that the
Client considers has occurred in their and/or the Supplier’s
compliance with Data Protection Laws.
1.11 The Client shall be obliged to maintain the public
register of processing where and when required in accordance
with Article 30 GDPR.
ACCEPTABLE USE POLICY
The Supplier's Acceptable Use Policy ("Policy") is intended to help
protect the Supplier service, clients and the Internet community
in general from irresponsible or, in some cases, illegal activities,
and the Client agrees to be bound by the Policy.
1. The Client and their end users shall not, nor shall they permit,
enable, or assist others, to use the Services for any breach of any
applicable local, national or the international law or regulation or
generally accepted transmission or application protocols
applicable to the Internet or any part of it or to anything
connected to it or to any user of it. Such prohibited use includes
but is not limited to the following:
a. civil infringement of and/or criminal offences relating
to IPRs; or
b. commission of any criminal offence (including
deliberate transmission of computer viruses) under
the Computer Misuse Act 1990 (UK) or any similar
legislation in any country; or
c. knowingly or recklessly transmitting, displaying or
posting to a publicly accessible service any material
which is unlawful or actionably defamatory or an
invasion of privacy, breach of an intellectual property
right or breach of a right of publicity in any jurisdiction
with which any publicly accessible service reasonably
appears to have any connection or from which it may
reasonably be apprehended that a publicly accessible
service is likely to be significantly accessed; or
d. transmitting, transferring, displaying or posting to a
publicly accessible service any material in breach of
the Data Protection Act 1998 (UK), GDPR or similar
legislation in any other country or of any material
which is confidential or is a trade secret or which
affects the national security of the United Kingdom or
the said territory or which may expose the Supplier to
any liability, loss or penalty under the laws and/or
regulations and/or decrees of the United Kingdom or
any other country relating to the export of or dealing
with military or potentially military resources; or
e. use of the Services or the Internet in any manner
which is a violation or infringement of any rights of any
kind or nature (whether similar to any of the foregoing
or otherwise) of any person; or
f. any sending of unsolicited email messages or any mass
mailing of unsolicited advertising material by the
Client; or
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g. any activity that potentially could harm the Supplier
Network, its clients' networks or other networks,
including traffic flooding, malicious overflows, etc; or
h. any activity that the Supplier decides at its absolute
discretion is an unsuitable use of the Services (and any
failure or delay to exercise its discretion shall not be
taken as approval or condoning of such use).
2. The Client is responsible for:
a. The activities of its customer base or end-users and, by
accepting service from the Supplier, is agreeing to
ensure that its clients abide by this Policy. If
irresponsible or illegal activity continues, even after
the Supplier tries to communicate with the Client,
then the Client may be subject to an appropriate
action in order to stop those activities.
3. IRC services or IRC-related services are not permitted. This
includes, but is not limited to: "IRCd servers," "eggdrops," "bots,"
and "bouncers." The purpose of this restriction is to prevent
attacks on the Supplier service due to malicious activity that has
been known to occur on the IRC networks EFnet and Undernet.
4. The Client warrants that it will respond to any Abuse
Complaints within 24 hours and urgently respond and comply
with all take-down or similar notices or requirements.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The 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, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Website, if not stated otherwise within this document.