GDPR/Privacy Policy

 

 

Simon Jones t/a Zako Media

Rev 1.1 25 May 2018


 

1. Introduction

This policy explains why, when and how we collect personal information from the people who visit our website, sign up or purchase any of our services or request or contact us in any other manner. The policy also details the conditions under which we may disclose the information to others and how we keep it secure.

While we encourage clients to read our privacy policy in full, we do have several base principles we operate by:

Tick Bullet         We will never sell your data on.

Tick Bullet         We will never share your data for marketing to by any third parties.

Tick Bullet         We will always keep your personal data secure using strong encryption, abiding by data protection rules and by implementing good security practice.

These policies have been adhered to since business foundation in 2004 and has always been the case. If you are ever concerned or have question about how your personal data is collected or used, please contact me at simon@sipa.co.uk

You can read our full privacy policy below.

2. About us

Simon Jones, trading as Zako Media is a UK based web hosting business operating from the address:

39 Gwynfor Road
Cockett
Swansea
SA2 0XF

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act) and GDPR (General Data Protection Regulation), the data controller is Simon Jones, 39 Gwynfor Road, Cockett, Swansea, SA2 0XF

3. When do we collect your personal data

We may collect data about you in the following ways:

Tick Bullet         By filling in forms on our website, this includes information provided at the time of registering to use our websites, subscribing to any of our services, posting material or requesting further services.

Tick Bullet         If you contact us, we will keep a record of that correspondence.

4. What personal data do we collect

If you are simply viewing our website then we will collect the following information within our logs: IP Address. This information is held for 1 month on the live server then a further 2 months in backups. Some IP addresses will be processed by a program called failtoban, this blocks IP addresses from being able to access the server. IP addresses are kept indefinitely but are not linked to any person or individual.

If you sign up to use our services we will then collect the following information:

Tick Bullet         Name

Tick Bullet         Address

Tick Bullet         Email Address(s)

Tick Bullet         Telephone number(s)

Tick Bullet         IP address

While not actively collected we may store any other personal information that you may disclose during live chat, tickets or emails.

5. Cookies and IP Addresses

IP Addresses

We collect IP address information for security (DDoS prevention, anti-hacking and fraud prevention), diagnostics and statistical analysis of traffic used for improvements to the performance and usability of our services, for GDPR purposes we collect this information under legitimate interest.

Cookies

A cookie is a small file saved on your computer that is used to help store preferences and other information that is used by websites you may visit.

We use cookies for the Following:

Tick Bullet         Analysis of traffic to our website via Google Analytics (see Google Analytics).

If you register with us or if you continue to use our site, you agree to the use of cookies.

You can block cookies by activating the setting in your browser which allows you to refuse the setting of all or some cookies.

Unless you have adjusted your browser settings so that it will refuse cookies, our system may issue cookies as soon as you visit our site.

6. Where we store and process your personal data

The data that we collect from you is stored in the UK and Germany but it may be processed by staff operating outside the EEA (European Economic Area) who work for us or for one of our suppliers. Such staff may be engaged in the provision of support services while working abroad. By submitting your personal data, you agree to the processing of this data outside of the EEA. Our primary server is based in Leeds, UK, however the company can and may move data to its secondary Germany based servers. Backups are accessed and stored using a self-managed system in Swansea UK.

We take all steps necessary to ensure that your data, regardless of where it is processed, is treated securely and in accordance with this privacy policy and the GDPR (General Data Protection Regulation).

7. How we protect your personal data

We treat all data with the utmost care and take appropriate steps in compliance with data protection regulation to ensure it is kept safe.

Tick Bullet         All data is stored behind firewalls managed by Heart Internet and Zako Media

Tick Bullet         All systems storing personal data have access logging.

Tick Bullet         All passwords are encoded at rest.

Tick Bullet         All systems are subject to regular penetration testing and are monitored for vulnerabilities and attacks.

8. Uses we make of personal data

We use information held about you in the following ways:

Tick Bullet         To verify your identity.

Tick Bullet         To provide you with the products and services you have purchased from us.

Tick Bullet         To carry out our obligations arising from any contracts entered into between you and us.

Tick Bullet         To ensure that content from our site is presented in the most effective manner for your device.

Tick Bullet         To respond to queries.

Tick Bullet         To provide you with information, products or services that you request from us where you have consented to be contacted.

Tick Bullet         To notify you about changes to our services.

Tick Bullet         To send you marketing emails where you have given explicit consent.

Tick Bullet         To display personalised Ads from us.

Tick Bullet         To prevent fraud.

Tick Bullet         To detect, prevent and diagnose potential security breaches.

9. Legal basis for the collection and processing

Data protection law sets out the conditions under which personal data can be collected and which we use as the basis for collection and processing, these include:

Contractual obligations

When you purchase a service, we need to collect personal data to fulfill our legal contractual obligation, for example: so we can manage and invoice your account and contact you for technical support purposes.

Legal compliance

The law requires we collect and process data for certain purposes such as for keeping financial records (i.e. invoicing) and that we can comply with law enforcement requests for data.

Legitimate interest

We collect data under legitimate interest in a way that is reasonably expected as part of the day to day running of our business.

For example, we collect and log IP addresses for fraud protection and security as well as analysis of our site usage.

10. How long we keep personal data

Your data will be kept until it is no longer required for the purpose of its collection.

At the end of the retention period the data will either be deleted or anonymised so it can no longer be linked back to an individual.

Personal data linked to purchases or any other financial transaction are kept for a minimum of 6 years as required by UK law to retain financial data.

11. Who we share personal data with

Like many websites we use a number of third-party services for functionality such as email sign-up and payment processing. The following is a list of companies we share data with on a day to day basis. This list does not include services we share anonymous data with or that provide services on an ad-hoc basis such as IT contractors. All the suppliers below have been carefully selected to ensure they provide suitable protections under GDPR.

Heart Internet

Heart Internet provide the infrastructure use to host all our websites. They donít have specific personally identifiable information, however they hold all databases and web content on my behalf and occasionally need to access it for support services. This data is never used for contact or distribution. Heart Internet may use this information to identify you in the case of catastrophe.

Privacy Policy: https://www.heartinternet.uk/blog/gdpr-and-heart-internet-frequently-asked-questions/

Gmail

Many emails received will be filtered through Gmail with 2 factor authentication. This includes invoices, personal contact details and conversations. As contacts and data are finished with, these are being phased out.

12. Google Analytics

Like many websites we use Google Analytics to collect anonymous data about the users of our sites such as how often they visit, what pages they visit, what time they visit, how long the stay and what country they are visiting from.

This data is collected using cookies and from your IP address, the resulting statistics are used for the following purposes:

Tick Bullet         Improving website usability

Tick Bullet         Tracking the success of marketing campaigns

Tick Bullet         Pattern analysis

You can prevent Google Analytics from collecting this information by installing the google opt-out browser addonhttps://tools.google.com/dlpage/gaoptout

To learn how Google uses data collected from our own and partner sites please see the following link: https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

13. Disclosure of your personal information

We may disclose your personal information to third parties:

If Zako Media or substantially all of its assets are acquired by a third party, in which case personal data held by it (Zako Media) about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions of supply Terms and Conditions and other agreements; or to protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

14. Your rights under GDPR

Under GDPR (General Data Protection regulation) you have a number of rights relating to your personal data, these will come into force on the 25th May 2018, for further information please see https://ico.org.uk

Right to Restrict Processing

You have the right to request we restrict processing of your personal data where there is no legitimate interest for us to do so:

Where the accuracy of the personal data is contested, to restrict the processing until such time as the accuracy has been sufficiently verified.

Where you object to the processing (See Right to Object), and where we are considering whether there are legitimate grounds to override the request.

When processing is unlawful and you oppose erasure and request restriction instead.

If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

You can exercise the right at any time by contacting our team (see Contacting Us).

Right of Access (Access to Information)

The GDPR Act gives you the right to access information held about you.

You can exercise this right by contacting us (see Contacting Us).

We are required to verify your identify before processing any right to access request, once verified the data shall be provided within 28 days.

The data shall be provided free of charge however an admin fee may be applied where a request is manifestly unfounded or excessive, particularly if it is repetitive.

Right to Erasure (Also known as the right to be forgotten)

As an individual you have the right to request the erasure of any data we hold on you, this is not an absolute right, for example it does not override our requirement under UK law to keep financial data such as invoice information.

You can make a request where your personal data is no longer necessary in relation to the purpose for which it was originally collected/processed, for example if you cancel all services you have with us.

To make a right to erasure request please contact our customer services team (see Contacting Us).

Right to Rectification

The GDPR provides the right to have any personal data rectified that may be incorrect or incomplete.

Customers can update their own personal details via the client area however if this is not sufficient please contact our customer services team (See contacting Us).

Right to Object

You have the right to object to the processing of your personal data where there is no legitimate or lawful reason to do so.

To make a right to object request please contact our customer services team (see Contacting Us).

15. Contacting us

Questions, comments and requests regarding this privacy policy are welcomed, you can contact us in the following ways:

Existing customers can contact us by creating a ticket through their client area.

Email us at simon@sipa.co.uk

Or write to us at: Simon Jones t/a Zako Media, 39 Gwynfor Road, Cockett, Swansea, SA2 0XF

16. Contacting the regulator

While we will make every attempt to rectify any situation, where you feel your data has not been handled appropriately you have the right to contact the regulator. In this case the regulator is the Information commissionerís office (ICO).

You can contact them on 0303 123 113 or by visiting https://www.ico.org.uk/concerns