Under the EU’s General Data Protection Regulation (GDPR) ‘Personal Data’ is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Identity Data includes first name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account, payment card details, and payroll data.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or intranet.
Profile Data includes your username and password on our website, our intranet, purchases or orders made by you, your preferences, and feedback and survey responses.
Usage Data includes information about how you use our website, intranet, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
4.2 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
4.3 Special Categories of Personal Data are 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 normally collect any special categories of data nor do we collect any information about criminal convictions and offenses other than for our employees or applicants for employment. However, if we do need to process such data we will ask for your explicit consent to do so.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or employee benefits). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
6.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by mail, phone, and e-mail or otherwise. This includes Personal Data you provide when you:
apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a promotion or survey;
give us some feedback;
provide unsolicited information to us;
apply for employment with us or when you become an employee.
6.2 Automated interactions. As you interact with our website or intranet, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, and other similar technologies.
6.3 Third parties (or publicly available sources). We may receive categories of Personal Data about you from various third parties (including other Zucchetti Group’s companies) and public sources as set out below:
7.3 Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
(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; to study how customers and clients use our products/services; to administer our employee relationships; to keep our employees updated on the activities, products and services of the other companies of Zucchetti Group and their partners.
To enable you to partake in a prize draw, competition or complete a survey
(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; to keep our employees updated on the activities, products and services of the other companies of Zucchetti Group and their partners
To administer and protect our business and our intranet and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests for running our business and employee relationship; provision of administration and IT services, network security; to prevent fraud; in the context of a business reorganization or group restructuring exercise. (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests to develop our products/services; to grow our business; to send invitations and providing access to guests attending events of Systopia International Inc. and/or of other Zucchetti Group’s companies.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will obtain your express opt-in consent before we share your Personal Data with any company outside Systopia International Inc. for marketing purposes.
: 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.
: Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Internal Third Parties: other companies or departments in the Systopia International Inc. or other Zucchetti Group’s companies (including parent companies, subsidiaries and affiliates) acting as processors or joint controllers who provide IT and system administration services and may provide reports to leadership.
External Third Parties: service providers acting as processors who provide IT and system administration services.
Other 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 Notice.
Professional advisers: acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting and payroll services.
12.2 Some of our external third parties as well as Zucchetti Group’s companies are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.
We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they adhere to Privacy Shield, which requires them to provide similar protection to Personal Data shared between the Europe and the US.
14.2 We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.