Privacy Policy
Our Websites and our app collect some Personal Data from its Users.
This document can be printed for reference by using the print command in the settings of any browser.
In addition to the information contained in this privacy policy, our Websites and our app may provide you with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
Who we are and what we do
Who we are and what we do
We are ZenOwn AG a company incorporated in Zug, Switzerland with registered number CH-170.4.016.968-7 (referred to herein as “we”, “us” or “our”, as the context requires)
Address: Baarerstrasse 82, 6300 Zug, Switzerland
Email: contact@zenown.com
We empower consumers brand through AI to enhance in-store execution and post-purchase engagement. For the purposes of the GDPR and any other applicable data protection laws, we are the controller of our website visitors, partners’, clients’ and prospects’ CRM data to the extent it pertains to natural persons.
This policy (together with our [Terms and Conditions] and any other documents referred to on them) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It applies to our website visitors, partners, clients, prospects and to other individuals whose data we may process as a controller, except for our employees (“you”).
We may change this policy from time to time so please, check our website occasionally for any updates. If we make material changes in the way we use your personal information, we may notify you by posting a notice on our website or sending you an email at the email address provided at the time of registration.
DPO CONTACT DETAILS
Aphaia Ltd
Eagle House
163 City Road, London,
EC1V 1NR
DPO Telephone: +44 20 3917 4158
Email address: dpo@aphaia.co.uk
UK REPRESENTATIVE
We have appointed Prighter as our representative in the UK. If you are in the UK and would like to address any concerns related to how we process your data or exercise your rights, you can contact Prighter using the contact details below or through this website.
Prighter Ltd (UK)
20 Mortlake Mortlake High Street
London SW14 8JN
UNITED KINGDOM Email address: info@prighter.com
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through our Websites (or third-party services employed in our Websites) or app, which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment
User
The individual using any of our Websites or our app who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of our Websites or app. The Data Controller of the Data gathered through our Websites or our app is ZenOwn.
Our Websites (or our App)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by our Websites and our app as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area and the UK.
Types of data collected
We may process either personal data provided by you directly, or, in case of Usage Data, personal data collected automatically when using this Website or our app. Among the types of Personal Data that our Websites and our app may collect, by themselves or through third parties, there are: Cookies (please see the ‘Cookies’ section below); Usage Data; name; company; email address; any other personal information provided when contacting us, for example through our forms.
If you are a partner or a client, we may collect your name and surname, email address, physical address, phone number, company and position and contract.
Users are responsible for any third-party Personal Data obtained, published or shared through our Websites or app and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
Legal basis of processing
We may process Personal Data relating to you if one of the following applies:
- You have given your consent for one or more specific purposes. In these cases, you can opt-out at any time by contacting us at contact@zenown.com or through any of the designated methods in each case.
- Provision of Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. Where this basis applies, we have undertaken the relevant Legitimate Interest Assessment to demonstrate that our compelling legitimate interest overrides the interests or the fundamental rights and freedoms of the affected data subjects. You can request further information about this by reaching us at contact@zenown.com.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing. You can contact us at contact@zenown.com for this purpose.
Purpose of processing
We use the data we collect from you in order to provide our Services, comply with our legal obligations, respond to enforcement requests, protect our rights and interests (or those of yours or third parties), detect any malicious or fraudulent activity, send marketing communications and for analytics.
When you contact us through our forms, we will use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header.
Analysis and predictions based on the User's Data ("profiling"): The Owner may use the Personal and Usage Data collected through ZenOwn to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Marketing
You may receive marketing communications from us if you have requested information from us or requested our services if, in each case, you have not opted out of receiving that marketing.
Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes.
We may share your email address with our partners for marketing purposes where you have opted-in to receive marketing communications from them.
We do not sell, rent or lease or provide in any other way our customer lists to third parties.
You may always object / opt-out by following the link in our email message or by sending us an email to contact@zenown.com. If you want to opt-out from our partner’s marketing communications, please check their website and the means enabled for such purpose.
Data disclosure
In addition to us, in some cases, the Data may be accessible to other parties in the ways described below:
- Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers, including cloud storage, mail carriers, analytics and communications providers, and system administrators or third parties who host and manage data;
- Analytics, CRM and other software that assist us in the communication with you and the improvement and optimisation of our website;
- Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers;-Other reasons
– We may also share your personal information with a purchaser or potential purchaser of our business.
-Any other third parties with your express consent.We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Place
The Data is processed at our operating offices in Switzerland and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, by ensuring at least one of the following safeguards is implemented:
-transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government;
-entering into specific contractual terms which have been approved by the European Commission or the UK Government and which give personal data the same protection as within the EEA and the UK. In these cases we will undertake a Data Transfer Impact Assessment in order to verify, on a case-by-case basis, whether the law in the recipient country ensures adequate protection for personal data transferred under this tool.
For further information on the safeguards used, please contact us at contact@zenown.com
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for or as otherwise required by applicable law.
When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between us and you shall be retained at least until such contract has been fully performed.
- Personal Data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfil such purposes in line with the Legitimate Interest Assessment.
We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted or anonymised.
The rights of Users
You may exercise certain rights regarding your Data processed by us:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Data. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out based on legitimate interest or for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Access your Data. You have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for it to be updated or corrected. We will need to verify the accuracy of the new data you provide to us.
- Restrict the processing of your Data. You have the right, under certain circumstances, to restrict the processing of your Data. In this case, we will not process your Data for any purpose other than storing it.
- Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your Data from us.
-Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
- Lodge a complaint with the relevant supervisory authority. You have the right to bring a claim before the competent data protection authority.
How to exercise these rights
Any requests to exercise User rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
Cookie Policy
This policy sets out how we collect and use personal data through cookies or other similar technologies. This policy should be read in conjunction with our Privacy Policy, available at https://www.zenown.com/privacypolicy
Type of cookies this website uses and purposes
Cookies are small text files that are placed on your computer by websites that you visit. We use necessary cookies to make our site work and we would also like to set optional cookies to help us improve it and give you the best experience possible.
The exact names of cookies we use on our website may change over time, however, the descriptions below set out the types of cookies that operate on our website. You can obtain an up-to-date list of the cookies we use by contacting us at contact@zenown.com
-Strictly necessary cookies. These are cookies that are required for the operation of our website, to provide services explicitly requested by you or to comply with any other legislation that applies to us, such as the security requirements of the GDPR. They include, for example, cookies that help ensure that the content of a page loads quickly and effectively.
-Analytical cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. We use them to collect information about how visitors access our services, such as the number of users on our website, how long they stay on the site for, and what parts of the site they visit. This helps us to improve the way our website work, for example, by ensuring that users are finding what they are looking for easily.
-Advertising cookies. These record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed to you more relevant to your interests and to understand that content’s effectiveness.
-Functionality cookies. These are used to recognise you when you return to our websites, which enables us to personalise our content for you and remember your preferences.
Lawful basis for processing
When you use our website for the first time you are given the opportunity to accept or decline not strictly necessary cookies. By using the toggles on the cookie banner, you are consenting to or declining our use of cookies by category as set out in this policy. You can also change your cookie consents at any time by accessing the cookie banner or by emailing us at contact@zenown.com.
Duration
Our use of cookies is proportionate in relation to our intended outcome and limited to what is necessary to achieve our purpose.
-Session cookies. These cookies allow us to recognise and link the actions of a user during a browsing session. They are temporary and expire at the end of a browser session, normally when you exit the browser.
-Persistent cookies. This category encompasses all cookies that are stored on a user’s device in-between sessions. All persistent cookies have an expiration date written into their code, but their duration can vary for each category or specific cookie. The persistent cookies we use normally expire after six months. If you require more information regarding the duration of a particular cookie used by us please contact us at contact@zenown.com.
How to manage your cookie preferences
You can set up your preferences the first time you visit our website and at any time through our cookie banner or by contacting us at contact@zenown.com.
You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Browsers also allow you to control access to cookies. You can find below the links providing information about how you can do this for the major browsers:
To find information relating to other browsers, visit the browser developer's website.
To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.