Privacy policy

Last updated on: 11-September-2024
Effective date: 11-September-2024

This privacy policy comprises the following Sections:

1. IMPORTANT INFORMATION AND WHO WE ARE

2. TYPES OF PERSONAL DATA WE COLLECT

3. HOW PERSONAL DATA IS COLLECTED

4. HOW PERSONAL DATA IS USED

5. DISCLOSURES OF PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. LEGAL RIGHTS

10. CONTACT DETAILS

11. COMPLAINTS

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

13. THIRD PARTY LINKS

1. IMPORTANT INFORMATION AND WHO WE ARE

Zeki Research Limited (registered in England and Wales with company number 13672518) (Zeki, we or us) is a data collector, aggregator and analysis business. We build and maintain unique databases from publicly available data sources from the internet, our own analysis and on companies, institutions and individuals across our areas of focus for the benefit of our customers.

This privacy policy gives you information about how Zeki Research Limited (Zeki, we or us) collects and uses your personal data through your use of this website or any other interaction with us. This includes any personal data you may provide to us when you register with us or sign up to our newsletters or other mailings available from us or when you purchase a product or service from us or enter into any other contract with us in accordance with our terms of business.

This privacy policy also applies to data subjects on whom personal information is provided by our suppliers and contractors and which we obtain through our own research and analysis of publicly available data sources from the internet. This privacy policy is intended to provide you with information on Zeki and how you can opt-out of our database and the potential outcomes of remaining in our database. You can opt-out of our database by following the steps in section 4 below.

By remaining in our database, you may be contacted by our customers when they are conducting their business and recruitment activities. Communications you receive from our customers may be relevant to your profession or employment role or profession.

Zeki as Data Controller

Zeki is the controller and responsible for your personal data. In some circumstances, Zeki may be a co-controller of your data with other third parties such as our customers or our service providers.

Data Protection Officer (DPO)

We have appointed a DPO who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (see section 9 below) then please contact us using the information set out in section 10 below.

The Zeki website is not intended for children and we do not knowingly collect data relating to children.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you by various means which we have categorised as follows:

Identity Data includes for example your name, any previous name(s), username or similar identifier, marital status, title, date of birth, gender, race and ethnicity.
Contact Data includes for example your billing address, delivery address, email address and telephone number(s).
Financial Data includes for example bank account and payment card details.
Transaction Data includes for example details about payments to and from you and other details of products and services you acquire from us (for payment or otherwise).
Technical Data includes for example internet protocol (IP) addresses, login data, browser types and versions, time zone settings and location, browser plug-in types and versions, operating systems and platforms, device ID and other technology on the devices you use to access this website.
Profile Data includes for example your username and password, purchases or other orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes for example information about how you interact with and use our website, products and services.
Marketing and Communications Data includes for example your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not undertake any obligatory collection of any special categories of personal data about you (this includes details about your race or ethnicity, religious beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We do infer race and ethnicity as part of our services. To the extent we do ever request any special category of personal data you will always be given the opportunity to decline to provide such information and this will not prevent you from accessing our website or continuing to receive our products or services.

3. How is your personal data collected?

We use different methods to collect your personal data including through:

Your interactions with us. You may give us your personal data by filling in online forms or by entering into service contracts with us or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

enquire about or apply for our products or services;
enquire about or subscribe to a service or publication;
request marketing to be sent to you or subscribe to our newsletter;
participate in a survey;
give us feedback or otherwise contact us;
enter into any contractual relationship with us.

Automated technologies or interactions. As you interact with our website and open our emails, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies but this data does not identify you individually. We infer race and ethnicity using software as part of our services.

We collect information either from third parties or publicly available sources (for instance social media platforms you have registered with). If we do obtain your personal data from a third party, your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.

Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

4. How we use your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to use your personal data to enter into and perform the contract we are or are to be party to with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or other report we publish.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we use the various categories of your personal data and which of the legal bases we rely on to do so.

Purpose/Use	Type of data	Legal basis and retention period
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you We will retain this data for the duration of the relevant contract and for any period after when we may still have liability to you under the contract.
To research, analyse, amalgamate and record information relating to individuals who are technical experts for the purposes of potential recruitment.	(a) Identity (b) Contact (c) Profile	Necessary for our legitimate interests (in order to deliver our services to our customers in pursuance of a contract). We will retain this data for two years.
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and to administer our own business) We will retain this data for the duration of the relevant contract and for any period after when we may still have liability to you under the contract
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries (including any raised through our website or otherwise through other enquiries made by you howsoever)	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you) We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business.
To enable you to participate in any surveys we may run	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business
To administer and protect our business (including our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). (b) Necessary to comply with a legal obligation We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent: having obtained your prior consent to receiving direct marketing communications. We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business
To carry out market research through your voluntary participation in surveys.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Consent: having obtained your prior consent to participate in a survey. Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). We will retain this data for the duration of our relationship with you and for any period after when we may still have liability to you and otherwise as is legitimate in relation to the administration and management of our own business

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view as to which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will not share your personal data with any third party for their own direct marketing purposes without obtaining your express consent.

Opting out of marketing

You may ask us to stop sending you marketing communications at any time by logging into the website and adjusting your personal preferences, by following the opt-out links within any marketing communication sent to you or by emailing us directly with your request, at escalation@thezeki.com.

If you opt out of receiving marketing communications, where relevant you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for any product/service warranty registration, appointment reminders, updates to our terms and conditions, checking that your contact details are correct and in any continuing performance of any contract we have in place with you.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below where necessary for the purposes set out in Section 4 above:

Third parties who perform services for us including assisting with data collection, analysis or processing and or in relation to production of reports or other business communications we produce and our database. We only permit these third parties to process your personal data for specified purposes and in accordance with our instructions.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Third parties to whom we provide our services as part of our business.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf or to third parties to whom we provide services. This may involve transferring personal data outside the UK or European Union to countries which have laws that do not provide the same level of data protection as the UK and EU law.

Whenever we transfer your personal data out of the UK or EU, we ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
We may transfer your personal data to our customers outside of the EEA where this is necessary to perform a contract between us and our customers; or
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, by the adoption of appropriate safeguards under Article 46(2) of the UK GDPR. This may include the adoption of the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers or by using an approved form of binding corporate rules. To obtain a copy of these contractual safeguards, please email us at us at escalation@thezeki.com.

6. Data security

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

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

7. Data retention

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in the table in Section 4 above.

In all cases, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, its source, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data (including our own commercial legitimate interests) and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes or to perform our services, in which case we may use this information indefinitely without further notice to you. It will not be regarded as personal data.

8. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see Opting Out of Marketing in Section 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in Section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you or others. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data’s accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at escalation@thezeki.com.

No fee usually required

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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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 speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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 keep you updated.

9. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your rights to correct or delete any data we might hold on you, please contact us in one of the following ways:

Email: enquiry@thezeki.com

Post: 71 – 75 Shelton Street, Covent Garden, London, WC2H 9JQ

10. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and it may be updated from time to time so please do revisit this page as necessary.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12. 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 policy of every website you visit.