Last updated: 9th June 2020

Purpose of this policy

This privacy policy aims to give you information on how Zento collects and processes your personal data as one of our customers or through your use of the zentoevent.com website (the ‘Website’). It makes you aware of how and why your personal data will be used and how long it will usually be retained for. It also provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

This policy primarily covers how we use information relating to our customers, prospects, Website visitors and people who interact with or do business with us. In these cases, we will be the “data controller” for the purposes of data protection law. There are also cases where we will be a “data processor” for the purposes of data protection law. Where you register for an event through the Website, we are processing your personal information on behalf of another organisation (the ‘Promoter’ or ‘Promoters’) in order that they can organise and administer their event. In circumstances where we are a data processor, it is the Promoter who decides what personal information to collect and how that information is used. Any questions that you may have relating to your personal information and your rights under data protection law in relation to a specific event should, therefore, be directed to the Promoter as the data controller, not to Zento.

It is important that you read this policy, together with our policy on cookies below and any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant and limited only to the purposes we have told you about.
• Accurate and kept up-to-date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

The type of information we collect about you

If you complete an online form, register for an event, communicate with us or do business with us, this will result in us collecting personal data about you. We will collect, store, and use the following types of personal information about you:

• Contact details such as your name, address, email address and telephone number.
• Personal information about you such as your age, date of birth and gender.
• Event-specific information such as your t-shirt size.
• Bank and transaction details such as details about payments to and from you and other details of products and services you have purchased from us.
• Technical information such as includes IP address, 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 the Website.
• Information about our service to you including your username and password, purchases or orders made by you, your preferences and any feedback you give us.
• Information about how you use the Website, products and services such as transaction attempts, successful order history and marketing and newsletter subscription preferences.
• Any other information you choose to provide in creating an account with us such as your social media profiles and event history.

When registering for an event, the information collected is determined by Promoters and we do not control the categories of information that are collected. We do not normally collect “special categories” of sensitive personal data from our customers or users of the Website. In the event you provide us with any special category data, we will take extra care to ensure your rights are protected.

How your personal information is collected

We collect your personal information through different methods including:

• Direct interactions with you by telephone, email, phone or otherwise.
• Through the service, we provide to you.
• Automated technologies or interactions. As you interact with the Website, we may automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For example, Zento may monitor how many times you visit the Website, which pages you go to, target Zento marketing and advertising campaigns, keep track of the items stored in your shopping basket, traffic data, location data and the originating domain name of a user’s internet service provider. The information assists Zento in building a profile of its users and improve your use of the Website by making it more efficient and enjoyable. Some of this data will be aggregated or statistical, which means that Zento will not be able to identify you individually.

How we may use your personal information

We will only use your personal information 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.
• Where 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, for example for HMRC reporting purposes.

Generally, we do not rely on consent as a legal basis for processing your personal information 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 such marketing at any time.

Purposes for which we use your personal information

We need the categories of information in the list above (see the type of information we collect about you above) primarily to allow us to perform our contract with you and to enable us to comply with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

• If you request a service or submit content to the Website, Zento will need your personal information in order to process your order and/or request.
• To assist in the identification of you and any accounts that you hold with Zento.
• To respond to your requests or to contact you via post, email or phone to inform you of changes to the Website or new products, services or promotions Zento may offer.
• To manage our relationship with you, including notifying you about changes to our contract or services or asking you to provide us with feedback.
• To administer and protect the business and the Website.
• For research, statistical analysis and behavioural analysis.
• To interact with you via social media channels should you provide your social profile details.
• For customer profiling and analysing your purchasing preferences.
• For fraud prevention and detection.
• To customise the Website and its content to your particular preferences.
• For the purposes of security vetting.
• To share your personal information with a Promoter.

If you fail to provide personal information

If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to register you for an event).

Change of purpose

We will only use your personal information 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing and opting out

Where you have given us consent to do so, Zento may contact you by (by post, email, telephone, SMS, fax, text/picture/video message) about services, promotions, special offers and charitable causes which may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time (see ‘Rights of access, correction, erasure, and restriction’ below).

Use of cookies

From time to time, information may be placed on your computer to allow us to identify you. This information is commonly known as “cookies”. By showing how and when our visitors use the Website, this information can help us to continue to improve the Website. We will only use cookies to view information on your hard drive that was put there by a cookie from the Website. Cookies are stored on your computer and not on the Website. If you do not wish to receive cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser so permits. For further information please see Zento’s cookie policy below.

Minors

No use of the Website, or information submitted via the Website, by or for persons under the age of 16 is permitted as Zento do not process child data.

Sharing your personal information

We may have to share your personal information with third parties, including third-party service providers. In such circumstances, we require third parties to respect the security of your personal information and to treat it in accordance with the law.

There may be circumstances where we are required to transfer your personal information outside of the European Economic Area (EEA), for example to third-party service providers located outside the EEA (see below ‘Which third-party service providers process my personal information?’). Whenever we transfer personal information outside of the EEA, we will comply with data protection law and ensure appropriate safeguards are in place to protect your personal information. For example, by only using providers that are EU-US Privacy Shield certified which means that it self-certifies to protect personal information received from the EEA.

Circumstances for sharing your personal information with third parties

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so. For example, we will share your personal information with the Promoter of the event that you have entered and with any Service Provider involved in the delivery of the event.

Circumstances where service providers may process your personal information

“Third parties” includes external service providers (‘Service Provider’ or ‘Service Providers’) including contractors and designated agents. The following activities are carried out by Service Providers: Website Developers, Server Hosting, Server Backup, Data Backup, Payment Processor, Email Provider, SEO Marketing, Analytics, Advertising.

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator, adviser, consultants or the police or to otherwise comply with the law.

All our Service Providers are required to take appropriate security measures to protect your personal information in line with our policies. You agreeing to our Privacy Policy does not allow our Service Providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Where appropriate you should be aware that use of a website owned by or services provided by a Service Provider may require you to agree to their Terms and Conditions and Privacy Policy.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach if and when we are legally required to do so.

Please note that while there are always risks associated with providing personal data, whether in person, by phone or over the internet, and no system of technology is completely safe, “tamper” or “hacker-proof”, Zento does have security measures in place such as storing your personal data on secure servers with encrypted disks and controlling your account by password and username unique to you. We endeavour to continually review these measures to prevent and minimise risks of unauthorised access to, improper use of, and also the accuracy of, your personal data.

Zento cannot guarantee the security or integrity of any personal data which is transferred from or to you via the internet.

Zento may monitor or record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Where we hold your personal information as a data controller, we will keep your personal information for up to 7 years following the termination of our service to you in order to comply with our legal and regulatory obligations. Where we hold your personal information as a data processor on behalf of a Promoter, the length of time we retain your personal information will be retained is determined by the Promoter and our own legal and regulatory obligations.

Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your business relationship with us.

Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, you should contact us by email (see details at foot of page). Please note, there are some specific circumstances where these rights do not apply, and we can refuse to deal with your request.

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email us (details at foot of page). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints

We take any complaints we receive about the collection and use of personal information very seriously. We request you to bring it to our attention if you think that our collection or use of information is unfair, misleading or inappropriate. You can make a complaint at any time by sending us an email (details at foot of page).

If you think our collection or use of personal information is unfair, misleading or inappropriate or if you have concerns about the security of your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. You can contact the Information Commissioner at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will place a revised privacy policy on this Website. We may notify you if we make any substantial updates or contact you from time to time about the processing of your personal information.

Cookies and how they benefit you

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. Our cookies help us:

• Make the Website work as you’d expect
• Remember your settings during and between visits
• Improve the speed/security of the Website
• Allow you to share pages with social networks like Facebook
• Continuously improve the Website for you
• Make our marketing more efficient (allowing us to offer our service at a fair price)

We do not use cookies to:

• Collect any personally identifiable information (without your express permission)
• Collect any sensitive information (without your express permission)
• Pass data to advertising networks
• Pass personally identifiable data to third parties
• Pay sales commissions

Granting us permission to use cookies

If the settings on your software that you are using to view the Website (your browser) are adjusted to accept cookies we take this, and your continued use of the Website, to mean that you are fine with this. Should you wish to remove or not use cookies from the Website you can learn how to do this below, however, doing so will likely mean that our site will not work as you would expect.

Website function cookies

We use cookies to make the Website work including remembering what you have entered and remembering your selected event and Promoter to help display relevant events. There is no way to prevent these cookies being set other than to not use the Website.

Social website cookies

So you can easily ‘Like’ or share our content on social networks such as Facebook and Twitter we may include sharing buttons on the Website. The privacy implications on this will vary from network to network and will be dependent on the privacy settings you have chosen on these networks.

Visitor statistics cookies

We use cookies to compile visitor statistics such as how many people have visited the Website, what type of technology they are using (e.g. Mac or Windows which helps to identify when the Website isn’t working as it should for particular technologies), how long they spend on the Website, what page they look at etc. This helps us to continuously improve the Website. These so called “analytics” programs also tell us if how people reached the Website (e.g. from a search engine) and whether they have been here before helping us to put more money into developing our services for you instead of marketing spend.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, may limit the functionality of the Website, and most other websites as cookies are a standard part of most modern websites.

If you are concerned about cookies relate to so called “spyware” rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

Contact us

Should you wish to contact us regarding our privacy or cookie policies please use the following:

• By Email – team(at)zentoevent(dot)com
• By Phone – 0333 7722 181 or from outside the UK: 0044 333 7722 181