Privacy Policy

Effective date: 28 June 2018

This Privacy Policy applies to services (zeroheight) owned and operated by Zero Height Limited. Zero Height Limited processes personal data as a Data Controller as defined in the GDPR. The lawful bases under which Zero Height Limited collects data under the GDPR are contractual necessity, legitimate interests and consent, as described in this Privacy Policy.

This Privacy Policy explains what information we collect when you access zeroheight, how the information is used, and how you can control the collection, correction and/or deletion of your information.

We won’t use or share your information with anyone except as described in this Privacy Policy.


1. What data we collect

zeroheight collects personal data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our service) provide personal data about you or when personal data about you is automatically collected in connection with your use of our service. We collect the following personal data from you in connection with the service:

  • Contact Information: information we collect to identify or contact you such as your name and email address.
  • Financial Account Information: financial information you provide, in order to process transactions when you purchase a plan (your card information is not held by us, it is collected by our third-party payment service providers Stripe, who are PCI-compliant and specialize in the secure online capture and processing of credit/debit card transactions). 
  • Transaction Information: information related to transactions you conduct on the service, for example the functionality you use and the links clicked on the service.
  • User Account Information: information that identifies you to the service, such as your name, email address, password, and IP address. For example, we use this information to authenticate you when you log in to the service, and use the IP address to help maintain your web session security while using the service. 
  • User Content:  to the extent that you choose to input personal data as part of such content, images, comments, and other content, information, and materials that you post to or through the service. Please do not provide us with any sensitive personal data whilst using the service.
  • Partner Information: information that our business partners, such as our content-providing partners, share with us — for example, if you use their services to purchase, preview, and/or otherwise use their content when using our service.
  • Log Data: information automatically recorded by the service about how a person uses our service, such as IP addresses, device and browser type, operating system, the pages or features of our website or service to which a user browsed, the time spent on those pages or features, the frequency with which the service is used by a user, search terms used by a user, the links on the service that a user clicked on or used, and other statistics.

2. How we collect data

We collect personal data when a user (i) creates an account (a “User Account”); (ii) logs into the service; (iii) interacts with the service; (iv) uploads or generates User Content; (v) communicates with us; and (vi) responds to a communication or interaction from us. Some of the methods and tools we use to collect personal data are:

Unique Identifiers: We use unique identifiers such as cookies, e-mail or your pseudonymized customer ID to track individual usage behavior on our service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our service on an individual basis.

Cookies, Web Beacons, and Other Tracking Tools: We and our third party service providers collect information about you, your device, and your use of the service through cookies, clear gifs (a.k.a. web beacons/web bugs) (“Web Beacons”), and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our service, the parts of the service accessed, the length of time spent on a page or using a feature, and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the service, such as how often users visit our service, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the service.

Cookies Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our website or using our service, whereas “persistent cookies” are stored on your device for a period of time after you leave our website or service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our service, and how your use of the service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our service. For more information on cookies, including how to control your cookie settings and preferences, visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htmhttps://ico.org.uk/for-the-public/online/cookies/ and http://www.allaboutcookies.org/ 

Web Beacons: Web Beacons help us better manage content on our service by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send.


3. How we use data

zeroheight uses personal data to: (i) provide, administer, and improve our service; (ii) better understand your needs and interests; (iii) fulfill requests you make; (iv) personalize your experience; (v) provide service announcements; (vi) provide you with information and offers from zeroheight and our business partners; (vii) protect, investigate, and deter against fraudulent, harmful, unauthorized, or illegal activity and (viii) comply with legal obligations.

For example, we use personal data to:

  • Operate and improve the service
  • Learn more about our users and their internet behaviors
  • Target offers to users
  • Facilitate communications among and between users and the public in general
  • Evaluate eligibility of customers for certain offers, products, or services
  • Evaluate the types of offers, products, or services that may be of interest to users
  • Provide user support
  • Communicate with users regarding support, security, technical issues, commerce, marketing, and transactions
  • Facilitate marketing, advertising, surveys, contests, sweepstakes, and promotions
  • Administer the service, User Accounts, and transactions with respect to User Accounts
  • Enforce our contracts, administering and carrying out our obligations under contracts, and complying with the law
  • Publish aggregated data about usage trends, which may be derived from personal data
  • Complete corporate transactions such as mergers, sales of assets, or bankruptcies


4. Lawful basis for processing data

We will only use your personal data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of personal data because we need to process the data to provide you with the services. When we process data due to contractual necessity, failure to provide such personal data will result in your inability to use some or all portions of the service that require such data:
    • Contact Information
    • User Account Information
    • Financial Account Information
    • Transaction Information
    • User Content

  • Legitimate Interest: We process the following categories of personal data when we believe doing so furthers the legitimate interest of us or third parties:
    • Contact Information
    • Financial Account Information
    • User Account Information
    • Transaction Information
    • User Content
    • Partner Information
    • Log Data
    Examples of these legitimate interests include:
    • Operation and improvement of our business, products, and services
    • Marketing of our products and services
    • Provision of customer support
    • Protection from fraud or security threats
    • Compliance with legal obligations
    • Completion of corporate transactions

  • Consent: In some cases, we process personal data based on the consent you expressly grant to us at the time we collect such data. When we process personal data based on your consent, it will be expressly indicated to you at the point and time of collection.

  • Other Processing Grounds: From time to time we may also need to process personal data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

5. Opting out

  • Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
    • Delete existing Tracking Tools
    • Disable future Tracking Tools
    • Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
  • Regarding Do Not Track (“DNT”):  DNT is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers at this time.
  • Emails: You can opt-out of non-essential emails such as marketing emails by clicking on the unsubscribe link at the bottom of each such email. Note that you cannot opt-out of emails that are essential to providing zeroheight services such as for customer service, security, billing, legal and contractual obligations.
  • Withdrawing consent: Where you have consented to zeroheight’s processing of your personal data, you may withdraw that consent at any time and opt out of further processing by contacting support@zeroheight.com
  • If you would like to object to the further use or disclosure of your personal data for certain purposes, such as for marketing purposes, or if you would like to ask us to restrict further processing of your personal data, please contact support@zeroheight.com.


6. Accessing, correcting and deleting your data

You have the right to request a copy of some or all of your personal data — please email support@zeroheight.com to do so. We also want to make sure that your personal data is accurate and up-to-date, so please email us if you would like to amend or delete it.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 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 keep you updated.


7. How long we keep your data

We are required under UK tax law to keep your name, contact details and billing data for a minimum of 6 years (after which it will be destroyed). Other data will be deleted as and when there no longer is a lawful basis for processing it.


8. How and when we disclose your data

Disclosure to comply with the law

We may disclose personal data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the services and any facilities or equipment used to make the service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

Disclosure to third parties

We share personal data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to zeroheight services. These parties include:

  • Third parties who act for us or provide services for us, such as billing and credit card payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting, and database management services
  • Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance, and corporate governance

9. How we store and protect your data

We use commercially reasonable security measures to protect against the loss, misuse and alteration of your information under our control. Notwithstanding such measures, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the security of any information transmitted to or from our services. We also are not responsible for the actions of any third-parties that may receive any such information.

If you are located outside the UK and Ireland and choose to provide information to us, be advised that Zero Height Limited is located in the UK and processes your information in the UK and Ireland. By using the service under this Privacy Policy and our terms of service, you consent to the transfer of your information to the UK and Ireland.


10. Visiting other websites

Our website contains links to other websites. This privacy policy only applies to this website, so when you visit other websites, you should read their own privacy policies.


11. Changes to this Privacy Policy

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.


12. Contacting Us

If you have any questions, comments or want to raise issues about this Privacy Policy, please use the following details:

support@zeroheight.com

Zero Height Limited
18-26 Shacklewell Lane
London
E8 2EZ