ZYGO COMMUNICATIONS LIMITED
PRIVACY POLICY
THIS PRIVACY POLICY WILL APPLY TO YOU IF YOU USE THE WEBSITE AND/OR THE SERVICES.
1. Definitions
The following words and expressions shall have the following meanings:
‘Associated Companies’ means in relation to a company any subsidiaries or holding companies of the company and any other companies sharing the same holding companies;
‘Zygo’ means Zygo Communications Limited, a company incorporated in England with registration number 05487111, having its registered office at Lavender House, 36 Mossbury Road, Battersea, London SW11 2PB and its Associated Companies. For the avoidance of doubt, ‘we’, ‘us’ and ‘our’ shall also mean Zygo;
‘Contract’ means the contract for the provision of the Services, which may be entered into between you and Zygo, which incorporates the Terms;
‘Customer Service Message’ means any SMS or MMS message sent by Zygo to you relating to the Services;
‘IP address’ means the unique identifier for your computer or such other device through which you access the Website;
‘Location Data’ means the data that allows us to locate the position of your mobile telephone hand set;
‘Message’ means a message sent from or to your Mobile Phone by SMS or MMS via the ZygoHub (as defined in the Terms) which is not a Promotional Message or a Customer Service Message;
‘MMS’ means the Multimedia Messaging Service by which means Users send and receive messages that include multimedia content;
‘Mobile Phone’ means a mobile telephone handset, as is more particularly described in the Terms;
‘Network’ means the electronic communications networks used by Zygo to provide the Services and by the User for Mobile Phone services;
‘Personal Data’ means all data that identifies you and that is processed by us, for example, your name, address, email address and any data that forms part of the Preferences Data, and/or Traffic Data that could be used to identify you;
‘Preferences Data’ means all data that we process regarding your preferences. This will include the preferences that you provide to us via the Website and the data that we collect through your use of the Services (which may include data contained in the Messages you send and receive) and your responses to Promotional Messages. This may also include information we collect about you through your use of the Services, such as Traffic Data;
‘Promotional Messages’ means promotional messages sent to Users, as are more particularly described in the Terms;
‘Sensitive Personal Data’ means all data that you choose to provide to us, if any, regarding such matters as your race, religion, political opinion, health and sexual life;
‘Services’ means the mobile telephone messaging services provided to you by Zygo and any other services which Zygo may from time to time agree to provide to you, as are more particularly described in the Terms;
‘SMS’ means the Short Message Service by which means Users send and receive text messages;
‘Terms’ means the terms and conditions that govern the supply of Services by Zygo, as displayed on the Website;
‘Territory’ means the United Kingdom mainland;
‘Traffic Data’ means the data that we receive from the Network with respect to your use of the Services, for example the data relating to the number of Messages sent and received by you;
‘User’ means an individual who uses the Website and/or the Services and ‘Users’ shall be interpreted accordingly, ‘you’ and ‘your’ shall also refer to a User;
‘Website’ means the website operated by Zygo located at the URL www.zygohubs.com.
2. Use of Personal Data
2.1 Your Personal Data are held by Zygo and kept confidential on our secure database.
Processing which is necessary to provide the Services.
2.2 It is necessary for Zygo to process certain types of data, which may contain your Personal Data, in order to provide you with the Services, including:
2.2.1 processing Personal Data for administration and accounting and to respond to complaints;
2.2.2 processing Personal Data and Traffic Data to enable transmission of Messages, Customer Service Messages and Promotional Messages and for billing purposes; and
2.2.3 monitoring or recording your communications with us for quality control and training purposes.
2.3 Zygo may pass your Personal Data to third parties who will provide certain elements of the Services to you on Zygo’s behalf, however all such third parties will be bound to provide at least the same level of protection for your Personal Data as we provide.
By submitting a request for us to provide the Services to you, you give your express consent for Zygo to pass your Personal Data to such third parties.
Processing for the purpose of tailoring the Services.
2.4 Subject to the Terms, the Messages and Customer Service Messages you receive may contain advertisements and promotional material of Zygo and third parties and, if you have given your consent, you may also receive Promotional Messages.
2.5 Zygo shall, where applicable, process your Personal Data, Preferences Data and Traffic Data to ensure that the advertisements and promotional material contained in any Messages, Customer Service Messages and Promotional Messages we send you are tailored to your interests. By using the Services you expressly consent to Zygo using such data for this purpose.
2.6 Zygo shall also process your Personal Data, Preferences Data and Traffic Data to ensure that the content of the Website and the products and services that we offer are tailored to your needs and interests.
2.7 Occasionally, the Preferences Data may include Sensitive Personal Data. You are under no obligation to provide such Sensitive Personal Data to Zygo and we will never process such Sensitive Personal Data unless you have chosen to provide it to us. By providing us with Sensitive Personal Data, you expressly consent to our using such data for the specific purpose for which it was provided and also for the purpose set out in paragraphs 2.5 and 2.6 above.
Processing required by law.
2.8 We may provide Location Data to the emergency services (including the Fire Service, Police, Ambulance Service and Coastguard) in the event that we receive a request from them for any reason. We may also provide any of your data to a third party where we are required to do so by law.
Further information and withdrawal of consent.
2.9 If you have any questions about how we use Your Personal Data, please contact us by writing to Zygo Communications Ltd, 36 Mossbury Road, Battersea, London, SW11 2PB or by email on support@zygocommunications.com
2.10 You may withdraw your consent or object to any of the processing carried out in accordance with this Privacy Policy at any time, however, please note that if you do so this may result in withdrawal of the Services.
3. IP address and cookies
3.1 When you visit the Website, we may log your IP address.
3.2 We may also store information about you in a cookie, which we can access when you make return visits to the Website. Sending cookies is usual practice for any web site that needs to remember what its users’ preferences are and we use cookies to keep track of your choices in this site (such as login or registration identification, login time, user preferences etc.)
3.3 A ‘cookie’ is a piece of text that a website transfers to a directory on your computer’s hard disk, so that the website can remember who you are. It will typically contain the name of the website from which it has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. Allowing a website to create a cookie does not give that or any other website access to the rest of your computer, and only the site that created the cookie can read it.
3.4 If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that cookies are stored in.
3.5 You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.
You have two options if you wish to disable cookies:
1) You may opt out of the third party cookies used on this site by following a few simple steps which can be found at http://www.websidestory.com/privacy/
2) You may disable cookies through your browser by following the instructions found at www.allaboutcookies.org/manage-cookies/
Further information about deleting or controlling cookies is available at www.aboutcookies.org.
3.6 Some of our web pages may contain electronic images known as Web beacons (sometimes known as clear gifs) that allow us to count the number of visitors to these pages. Web beacons collect only limited information which including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
Further information about web beacons is available at www.allaboutcookies.org/web-beacons/
4. Data Storage and Security
4.1 We take appropriate measures to ensure that Your Personal Data are kept secure and are kept for only so long as is necessary for the purpose for which they are used.
4.2 If there is any change in the personal data that you have provided to us through the Website you must use the Website to update such personal data. In such event Your Personal Data will be updated as soon as you submit the new personal data to us. If you provide updated personal data to us by any other method, we will amend our records within 30 days of receipt of such updated personal data.
4.3 We will store the personal data that you provide to us through the Website or otherwise for so long as you are a registered member. After you cease to be a registered member we will keep Your Personal Data on our records for a period of 2 years to enable us to respond to any queries or complaints that you may have. After this time we will delete all of Your Personal Data from our records, apart from any data that we are required to keep for legal reasons - for example we need to keep some financial data, which may include Your Personal Data, for 7 years in order to comply with English tax rules.
4.4 We will store records containing your IP address, Traffic Data and Preferences Data for 2 years from the date on which the data was collected, after which such data will be deleted or anonymised.
5. Third Party Personal Data
5.1 If you have provided us with data about another person, you confirm that they consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed.
6. Third Party Websites and Advertisements
6.1 You can access a variety of other websites from our Website, we display advertisements from third parties on the Website and we transmit advertisements for third party products and services to your Mobile Phone by SMS and MMS message.
6.2 We are not responsible for the privacy policies of these websites and third party advertisers, nor for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers.
7. Your Rights
7.1 You are entitled to ask for a copy of any personal data that we hold about you (for which we may charge a small fee) and to have any inaccuracies in Your Personal Data corrected.
8. Changes to this Policy
8.1 We may revise this policy at any time by posting the revised policy on the Website. Your continued use of the site will mean that you accept those revisions.