In short:We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
Zerri GDPR and UK GDPR Policy
Data Protection Principles. Zerri adheres to the principles of the UK GDPR, ensuring that personal data is:
- Processed lawfully, fairly, and in a transparent manner.
- Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.
- Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Lawful Basis for Processing. Zerri will only process personal data when we have a lawful basis for doing so, as defined by the UK GDPR. This may include:
- Consent: Where an individual has given clear consent for us to process their personal data for a specific purpose.
- Contract: Where processing is necessary for the performance of a contract with the individual or to take steps at their request prior to entering into a contract.
- Legal obligation: Where processing is necessary for compliance with a legal obligation to which Zerri is subject.
- Legitimate interests: Where processing is necessary for the purposes of the legitimate interests pursued by Zerri or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
Legitimate Interests Assessment (LIA) for sales and marketing activities. Zerri conducts business-to-business (B2B) sales and marketing activities to promote our services and expand our client base. We use GDPR compliant data enrichment platforms to identify potential clients and gather relevant business contact information. We have conducted a Legitimate Interests Assessment (LIA) to ensure that our processing activities are compliant with the UK GDPR.
Purpose of processing. The purpose of processing personal data in this context is to:
- Identify and contact potential clients who may benefit from our services.
- Provide information about our services that are relevant to their business needs.
- Develop and maintain business relationships.
Legitimate interests pursued. Zerri has a legitimate interest in:
- Growing our business and expanding our client base.
- Offering our services to businesses that may benefit from them.
- Networking and building relationships within the industry.
Necessity of processing. The processing of personal data for these purposes is necessary because:
- Identifying and contacting potential clients is a fundamental aspect of B2B sales and marketing.
- Providing relevant information about our services enables potential clients to make informed decisions.
- Maintaining business relationships is essential for long-term success.
- Send users information about offers and development of our products and services.
- Develop and display personalised and relevant advertising content for our users.
- Analyse how our Services are used so we can improve them to engage and retain users.
- Support our marketing activities.
- Diagnose problems and/or prevent fraudulent activities.
- Understand how our users use our products and services so we can improve user experience.
Balancing test. We have balanced our legitimate interests against the rights and freedoms of the data subjects. We believe that our processing activities do not unduly infringe on these rights because:
- We only process data that is relevant to their professional roles (job titles, business email addresses).
- We provide clear and easy opt-out mechanisms in all our marketing communications.
- Individuals would reasonably expect their business contact details to be used for professional networking and business-related communications.
- The data is obtained from sources in the public domain that are intended for business use.
Data sources. Zerri uses 3rd party data enrichment platforms which comply with UK GDPR to obtain personal data for B2B sales and marketing purposes:
Data minimisation. Zerri is committed to data minimisation. We only collect and process the minimum amount of personal data necessary to achieve our legitimate interests. This typically includes:
- Name
- Job title
- Business email address
- Company name
- Company address
- Industry
Data subject rights. Zerri respects the rights of data subjects under the UK GDPR. Individuals have the right to:
- Access: To request a copy of their personal data.
- Rectification: To request that inaccurate or incomplete data be corrected.
- Erasure: To request that their data be deleted (in certain circumstances).
- Restriction of processing: To request that the processing of their data be restricted (in certain circumstances).
- Object: To object to the processing of their data, including processing for direct marketing purposes.
- Data portability: To receive their data in a structured, commonly used, and machine-readable format.
Opt-out mechanism. Zerri provides a clear and easy opt-out mechanism in all our email marketing communications. Individuals can unsubscribe from our emails or other communications at any time by following the instructions provided in the communication. We also honour opt-out requests received through other channels.
Data security. Zerri has implemented appropriate technical and organisational measures to ensure the security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These measures include:
- Encryption: Using encryption to protect sensitive data.
- Access controls: Limiting access to personal data to authorised personnel.
- Regular security assessments: Conducting regular assessments of our security measures.
- Employee training: Providing regular training to our employees on data protection best practices.
Data retention. Zerri will only retain personal data for as long as is necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting requirements.
Data transfers. Where Zerri transfers personal data to countries outside the UK, we will ensure that appropriate safeguards are in place to protect the data, in accordance with the UK GDPR. This may include:
- Transferring data to countries that have been deemed to provide an adequate level of protection by the UK government.
- Using Standard Contractual Clauses approved by the UK government.
Policy review. This policy will be reviewed and updated regularly to ensure that it remains compliant with the GDPR and UK GDPR and reflects our current data processing practices.
Email communication. To ensure transparency and inform recipients about our data processing practices, Zerri will include the following in our email communications, as appropriate:
- A clear and conspicuous link to our full GDPR Privacy Policy.
- A brief statement in the email footer indicating the source of the recipient’s data: In the legitimate interest of Zerri’s business we may have sourced your contact details from GDPR compliant data enrichment platforms.
Complaints. Individuals have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if they believe that Zerri has not complied with the requirements of the UK GDPR.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations