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Privacy Policy

| INTRODUCTION |

This Privacy Notice provides you with details of how we collect and process your personal data through your use of our site https://www.zolo.co.im, how to contact us, how long we may keep your data and your rights.

By providing us with your data, you warrant to us that you are over 18 years of age.

Zoe Lowey is the data controller and ZoLo are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

 

| CONTACT DETAILS |

We are ZoLo Creations Limited, ZoLo, and our contact details are as follows:

Website: www.zolo.co.im

Email: hello@zolo.co.im

Phone: 07624 309439

Address: 38 Hillcroft, Douglas, Isle of Man IM2 7DR

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@zolo.co.im.

 

| WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUNDS WE PROCESS IT |

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any hire of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, and purchase details. We process this data to supply the goods and/or services you have hired and to keep records of such transactions. Our lawful ground 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.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interest which in this case is to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business, and to decide our marketing strategy.

We may use Customer Data, User Data, and Technical Data to deliver relevant website content and advertisements to you (including Meta adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is a legitimate interest which is to grow our business.

 

| SENSITIVE DATA |

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but, if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose as necessary. For more information on this please email us at hello@zolo.co.im. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing the same.

We may process your personal data without your knowledge or consent where this is required or permitted by local law.

We do not carry out automated decision making or any type of automated profiling.

 

| HOW WE COLLECT YOUR PERSONAL DATA |

Data can be collected by you providing the data directly to us (for example by filling in forms on our website or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

We may receive data from third parties by analytics providers such as Google based outside the EU, advertising networks such as Meta based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

We may also receive data from publicly available resources.

We are committed to using lawful and fair means to collect personal information and collecting it from others only when it is unreasonable or impracticable to obtain certain information from you directly.

Third parties may also use cookies, web beacons and similar technology to collect or receive information from our website or from you and from elsewhere on the internet and use that information to provide measurement services and targeted advertising (such as the Facebook pixel, Google Analytics and AdWords). If we receive your personal information from third parties, we will protect it as set out in this Privacy Policy.

We will destroy or de-identify information where we form the opinion that the information has been provided to us unlawfully or unfairly.

 

| HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION |

Access: You can request details of personal information that we hold about you. We will respond to any request to access information within a reasonable time.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details set out in this Privacy Notice. We rely in part on you advising us when your personal information changes. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date and to notify you of the correction, unless it is impracticable or unlawful to do so.

Deletion: If you want us to delete personal information we hold about you or to not collect information from you for a specific purpose, please contact us using the details set out in this Privacy Notice. Please note that if we agree to delete your information, because of backups and records of deletions, it may be impossible to completely delete your information without retaining some residual information. We will functionally delete the information and we will not sell, transfer, or use personal information relating to you in any way moving forward.

 

| HOW I MAINTAIN THE SECURITY OF YOUR INFORMATION |

We’re committed to ensuring that the personal information we hold is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure. We undertake the following precautions to protect personal information we hold:

  • Our website contains pages encrypted with SSL (Secure Sockets Layer) to ensure the safety of any data that is submitted through the use of com
  • We limit access to personal information to a “need-to-know” basis.
  • We protect devices we use to collect, hold, use and disclose personal information with industry-standard anti-virus software
  • Our devices are stored in secure premises
  • All data is securely stored on cloud servers
  • We do not hold ‘hard copies’ of personal information
  • All conversations involving the discussion of personal information take place in private, where conversations are unable to be overheard by unauthorised personnel
  • if we no longer need personal information, we will take reasonable steps to delete the information

While we take commercially reasonable measures to maintain a secure website and business, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to you for any such occurrences.

 

| MARKETING COMMUNICATIONS |

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@zolo.co.im at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty, registrations etc.

 

| DISCLOSURES OF YOUR PERSONAL DATA |

We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers

Government bodies that require us to report processing activities.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

| INTERNATIONAL TRANSFERS |

We do not transfer your personal data outside the Isle of Man, United Kingdom, or EEA so far as we are aware.

 

| DATA SECURITY |

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

| DATA RETENTION |

We will only retain your personal data 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

| YOUR LEGAL RIGHTS |

Under data protection laws you have certain rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

You can see more about these rights at:

https://www.inforights.im/individuals/data-protection/your-data-protection-rights/

If you wish to exercise any of the rights set out above, please email us at hello@zolo.co.im.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to expedite our response.

We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and provide an anticipated timeframe.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Isle of Man Information Commissioner (ICO), the Isle of Man supervisory authority for data protection issues a s their contact details are as follows:

 

Website: www.inforights.im

Email: ask@inforights.im

Phone: 01624 693260
Address: P.O. Box 69, Douglas, Isle of Man, IM99 1EQ

We respectfully request that you contact us in the  first instance so that we can work to resolve this for you.

 

| THIRD-PARTY LINKS |

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice on each website you visit so you know how your data is being used.

 

 | COOKIES |

As you probably know, a cookie is a small text file that’s placed on your computer to help us remember your preferences, like your login information or location. Cookies are used for a variety of reasons. We use cookies to make it easier and faster for you to use ourwebsite. We also use cookies for security purposes to protect you online.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

| REVIEW |

This Privacy Notice was last reviewed on 18 January 2023.