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Privacy Policy

 

Last Updated: 16 September 2019

 

This Privacy Policy explains how Zone Manager Ltd collect, use, and share information from or about you when you use our websites, web based services, downloadable applications, other digital services  and off-line services that link to this policy,  or if you engage in business with us (“ Zone Manager Ltd Services or Services”).

This Privacy Policy applies to the Zone Manager Services throughout the world. Any additional privacy terms that relate to specific Zone Manager Ltd products or services should be read in conjunction with this Policy.

We offer Zone Manager Services through our Zone Manager web-based delivery management system and custom systems which may have different branding. The data controller of your personal information will be the Zone Manager Ltd company which provides services to you or does business with you.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ AND UNDERSTAND THE PRIVACY POLICY AND THAT WE WILL COLLECT, USE AND SHARE YOUR INFORMATION AS SET FORTH BELOW.

1. PERSONAL INFORMATION WE COLLECT AND PURPOSES

The tables below explain the categories of information we collect or may in future collect, and the purposes for which we use them.  Each Zone Manager Ltd Service’s collection and use may vary. Please note that we may use any or all of this information to comply with the law, detect or prevent fraud, and to defend our legal rights. Further detail about each of the purposes is set out in the “Additional Information on Purposes” table below.

Categories of personal information we collect Purposes of use
Information you provide to us:

Contact information and account registration

For example: name, email, postal address, telephone number, account user name and password, business contact information, and any information you may provide to us at an event or in person.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Send you marketing communications

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Build and manage business-to-business relationships

·         Market and advertise for third parties

Identification and demographics

For example: date of birth, gender, nationality, ethnicity, interests, lifestyle information, photos, social media credentials, including identification information about friends, contacts or referrals you provide.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Send you marketing communications

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Market and advertise for third parties

Transactional

For example: credit/debit card details, purchase history, delivery address, membership information, reservations, and the personal details of any of your guests.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Send you marketing communications

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Market and advertise for third parties

User-generated content

For example: photos, videos, audio, and other information you may submit to us.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Send you marketing communications

·         Protect our users, Services and properties

·         Market and advertise for third parties

Research and feedback

For example: comments that you send us through online forms and social media platforms, by email, over the phone, by mail, or in surveys.

·         Provide the Zone Manager Services

·         Personalize your experience

Biometric identifiers

For example: facial scans or fingerprints.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Protect our users, Services and properties

Audio and video

For example: audio recordings of a customer service call or security video footage if you visit one of our properties.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Protect our users, Services and properties

 

 

Categories of personal information we collect Purposes of use
Information we collect automatically from you and/or your device:

Device information and identifiers

For example: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Market and Advertise for third parties

Connection and Usage

For example: domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded to us when you next connect.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Send you marketing communications

·         Market and advertise for third parties

Geolocation

For example: city, state and postal code associated with your IP address or derived through Wi-Fi triangulation.

We will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Provide seamless experience across platforms and devices

·         Protect our users, Services and properties

·         Send you marketing communications

·         Market and advertise for third parties

 

 

Categories of personal information we collect Purposes of use Source of Information
Information we collect from third parties:

Information from public and commercial sources

For example: demographic including at a household level, contact information, inferences about your preferences, loyalty program membership, and purchasing data.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Provide seamless experience across platforms and devices

·         Send you marketing communications

·         Build and manage business-to-business relationships

·         Market and advertise for third parties

·         Advertising providers

·         Analytics providers

·         Marketers

·         Partners (such as for sweepstakes partners)

·         Consumer data resellers

·         Public records databases

·         Related Companies

Social Media Information

For example: if you interact with us through a social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments about our Services, and the people/sites you follow.

·         Provide the Zone Manager Services

·         Personalize your experience

·         Send you marketing communications

·         Provide seamless experience across platforms and devices

·         Social media networks

·         Partners of social media networks

 

 

Additional information that we collect for business relationships only
Categories of personal information we collect Purposes of use Source of Information

Business contact information

For example: company name, your name, email address, and job.

·         Build and manage business relationships

·         You

·         Your company

·         Trade associations

·         Social media

·         Business data resellers

Due diligence information

For example: contact information, nationality, job title, age, date of birth, gender, country of residence, employment and education information, public, religious, political or trade union roles, personal and professional affiliations, connections to criminal activities or offences related to money laundering.

·         Compliance and risk management activities for business relationships

·         Your or your company’s responses to our due diligence questions

·         Third party compliance screening tools and databases.

 

 

Additional information on purposes of use

Provide the Zone Manager Services, for example:

·         responding to your requests or inquiries, including technical support

·         sending you service-related communications

·         providing ticketing, payment services, mapping guidance, and offers

·         displaying content you generate, such as video and comments

·         carrying out research and analytics for uses including improving our Services and developing new ones

·         processing your information for promotional campaigns such as sweepstakes and contests, and for surveys, online and offline panels and focus groups

Personalize your experience, for example:

·         providing you with customized product experience, including personalized newsletters, viewing and other content recommendations from Zone Manager Ltd, our partners and other organizations

·         providing you with advertising based on your activities and interests including at a household level

·         creating and updating profiles and audience segments that can be used for analytics, interested-based advertising and marketing on the Zone Manager Services, third party services and platforms, mobile apps and/or websites, connected devices and offline using inferences about your preferences and interests for any and all of the above purposes

Send marketing communications (with consent if required), for example:

·         sending you newsletters, surveys and information about products, services and promotions offered by Zone Manager Ltd

Provide a seamless experience across platforms and devices, for example:

·         identifying you when you log into the Zone Manager Ltd Service on multiple devices or web browsers to provide continuity and to match your interests across devices for the purposes of analytics, advertising, reporting and to improve the Services

·         identifying you if your devices have attributes suggesting that they may be used by the same individual or household for purposes of analytics, advertising, reporting and to improve the Services

Build and manage business relationships, for example:

·         pursuing potential business opportunities, including identifying and contacting the correct person within the company

·         sending communications for business purposes

·         sending event invitations, marketing emails and campaigns, and tracking the effectiveness of such communications

·         providing business contacts with access to our systems, and managing that access

Market and advertise for third parties, for example:

·         send you newsletters, promotional emails, surveys and information about products, services and promotions offered by our partners and other organizations with which we work

·         customize content that our third-party partners deliver on the Services (e.g., personalized third-party advertising)

·         create and update inferences about you and audience segments that can be used for interested-based advertising and marketing on the Services, third party services and platforms, and mobile apps

·         create profiles about you, including adding and combining information we obtain from third parties and matching your interests across devices, which may be used for third-party marketing and advertising on the Zone Manager Services, television, third party services and platforms, mobile apps and/or websites, connected devices and offline

Compliance and risk management activities for business relationships, for example:

·         compliance with laws and regulations

·         managing third party and other risks to our business

·         protecting the reputation of our businesses

·         following the principles of ethical business conduct set out in our Code of Conduct

Protect our users, Services and properties, for example:

·         protecting the safety and security of users and visitors to the Zone Manager Services

·         protecting our digital and physical properties

·         detecting and preventing other activities that may be illegal or in violation of our Terms of Service for that respective Zone Manager Ltd Service

We may combine all the information we collect from or receive about you for the outlined purposes. We may aggregate or deidentify your information and may use, share, rent or sell aggregated or deidentified information for any purpose, and such information is not subject to this Privacy Policy.

 

2. WHEN WE SHARE YOUR INFORMATION

We may share your information with:

  • Advertisers, Advertising Networks, and Other Third Parties: We may share information about how you use the Zone Manager Services and interact with content or ads to better tailor services, products, marketing and advertising on our Services and on third-party platforms. To enable these purposes, we may share certain demographics information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third parties may use their own tracking technologies to collect or request information about you, please see our Cookie Notice.
  • Partners: We may share your information with third party partners. For instance, if you enter a contest or sweepstakes sponsored by a third party, we may share the information you provide for that entry with the sponsor. Depending on the partnership, we may share certain information including contact information (at your direction), identification and demographic information, transactional information, user-generated content that you provide, research and feedback, device information and identifiers, connection and usage information, public and commercial information, and social media information.
  • Social Networks:We may share your information with social media platforms for example, if you click on a Facebook “like” button on an Zone Manager Ltd Service, the “like” may appear on your Facebook account. To control this sharing of information, please review and adjust your privacy settings for the relevant social network.   Depending on your privacy settings and actions on such network, we may share contact information, identification and demographic information, user-generated content, device information and identifiers, connection and usage data, and social media information.
  • Service Providers:We engage vendors to perform business purposes on our behalf and share information with them to enable them to provide us with such business purposes, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
  • Search Engines: Depending on the Zone Manager Ltd Service, you may be able to engage with other members of the Service or the public. This may make the name and photo associated with your profile and any comments or user-generated content you provide visible to other members of that Service or the general public. If the information is available to the general public, it may also be searchable by search engines.
  • Law Enforcement, Regulators, Anti-fraud Coalitions and other groups: We share any of the categories of information we collect, as appropriate, with these third parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.

Other Sharing

We may share information about you along with a hashed or masked identifier, with third parties so they may better personalize your experience with them and the offers they send you. With your appropriate consent when required, and consistent with applicable law, we may share your video viewing behaviour with third parties including service providers, advertising companies, analytic partners, and social media sites.

Sale or transfer of all or part of our business or assets

In the event that Zone Manager Ltd is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the information described in this Privacy Policy as part of that transaction.

 

3. Legal Bases for Use of Your Information

The laws of some jurisdictions, such as the European Union, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases:

  • Performance of a contract: where use of your information is necessary to provide you with Zone Manager Services under a contract, for example the relevant Terms of Service.
  • Legitimate interest: where use of your information is necessary for our or others legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:
    • providing Zone Manager Services
    • improving our Services and developing new ones
    • recognizing and better understanding our users, including across platforms
    • conducting security and fraud prevention activities
    • marketing and promoting our content and services
    • building and managing business relationships
    • conducting compliance and risk management activities
    • providing and managing access to our systems
  • Legal obligation: where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money-laundering, complying with requests from government bodies or courts, or responding to litigation.
  • With consent: we may ask for your consent to process your information in a certain way.  Where we rely on this basis, you have the right to withdraw your consent at any time – please see the Your Rights and Your Choices sections below to do this.

4. CHILDREN

The Zone Manager Services are only intended for users over 16 years.

5. YOUR RIGHTS

Depending on where you live, you may have certain rights with respect to your information. For example, under local laws, including in the European Union, you may be able to ask us to:

  • provide access to certain information we hold about you, in some cases in a portable format, if technically feasible
  • update or correct your information
  • delete certain information
  • restrict the use of your information

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.

Some Zone Manager Services can only be provided if we have your information, therefore deletion of your information will result in termination of such Services.

We will take reasonable steps to verify your identity, including authenticating you through the email address. We may require further documentation such as a password and user ID before granting access to your information.

If you have any unresolved concerns, you may have the right to complain to your local data protection authority.

6. YOUR CHOICES

Cookies and Similar Technologies

We and our service providers, advertisers, and other third parties use cookies and similar technologies (e.g., HTTP cookies, HTML 5, flash local storage cookies, web beacons, GIFs, embedded scripts, ETags/cache browsers, and software development kits) to recognize you on, off, and across Zone Manager Services and your devices. For more information about the use of cookies and similar technologies on the Zone Manager Services (including your opt-out choices) please see our Cookie Notice.

Mobile App and Connected Devices

Depending on the device you use, you may be able to manage your advertising and location preferences through your device settings and as outlined in our Cookie Notice.  Many operating systems provide their own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to manage personalized in-application advertisements. You should review your device manufacturer’s support materials and/or the device settings for the respective operating systems for more detail on how to manage such preferences.

You can stop all collection of information by a mobile app by uninstalling the app.

Third-Party Online Services

Zone Manager Services may contain links to third party services. These other sites (even if co-branded as Zone Manager Ltd) may collect information about you and use this information in accordance with their own privacy policies and terms of service. We do not control those third parties’ policies or practices. Where Zone Manager Ltd collects personal information on a co-branded website or service, we will provide a link to our privacy policy as appropriate. In some circumstances, Zone Manager Ltd may host some websites on behalf of others and those entities may place or permit the placement of cookies and other tracking technology. Zone Manager Ltd is not responsible for these tracking practices.

7. HOW WE PROTECT YOUR INFORMATION

We maintain organisational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible.

8. HOW LONG WE KEEP YOUR INFORMATION

We will keep your information only for as long as it is necessary to fulfil the purposes described above, unless a longer retention is required or permitted by law. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. The retention period that applies to your information may vary depending on the Zone Manager Services you use and how you interact with them. Some Zone Manager Services may provide additional details on their data retention practices, so we encourage you to consult their website and/or FAQs.

9. INTERNATIONAL TRANSFERS

Zone Manager Ltd is a UK based company with its headquarters in England.  We may transfer your information to Related Companies, service providers, and other third parties located outside of your country of residence. This is necessary to provide our Services and for the purposes outlined in this Privacy Policy.  Data privacy laws vary from country to country and may not be equivalent to, or as protective as, the laws in your home country.  We take steps to ensure that reasonable safeguards are in place with aim to ensure an appropriate level of protection for your information, in accordance with applicable law. These measures include data transfer agreements. By providing us with your information, you acknowledge any such transfer, storage or use.

10. UPDATES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes to our practices or the law. We will make the revised Privacy Policy accessible through the Zone Manager Services.  Please check the Zone Manager Services periodically for updates.

The date at the top of the Privacy Policy tells you when it was last updated. If we make material changes to the way we collect or use your information, you will be provided with appropriate notice, including by, but not limited to, posting the updated Privacy Policy on this website, and providing notice in accordance with legal requirements. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted.  By continuing to use the Zone Manager Services following any changes to this Privacy Policy, you acknowledge you have read and understand the updated Privacy Policy, and you understand that we will collect, use, and share information as stated therein.

11. CONTACT US

For any questions or complaints about this Privacy Policy or our privacy practices, please contact us at info@zonemanager.co.uk or Zone Manager Ltd, The Business Centre, Edward Street, Redditch, B97 6HA