Effective as of 1. June 2023
zerofy OÜ, registry code 14955228, Telliskivi 60A, Tallinn, 37, 10412, Estonia (hereinafter “Zerofy”, “we”, “us” or “our”) is the data controller of your personal data unless explicitly stated otherwise.
Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which in collection can lead to identification of particular individual, also constitutes as personal data.
Information about you will be collected, if provided by you through certain facilities on our Website or Mobile app, for example if you register a user account. The purpose of these facilities is apparent at the point where you provide your personal information and Zerofy only uses your information for those specific purposes, unless further processing is allowed.
Your data may also be collected from third parties such as social media platforms (e.g. Facebook, LinkedIn) that may share information about how you interact with our social media content (e.g. likes, comments). Also, if you are a potential client or a representative of our business partner we will collect personal data that is necessary to provide you our services.
3. Personal data collected, its purposes and legal grounds
3.1. Performance of agreements
Zerofy processes your personal data for the performance of the agreements concluded with you in accordance with our Terms of Service. When registering a user account, you enter into a legally binding agreement with us. This includes processing activities such as taking steps prior to entering into an agreement, as well as to conclude, amend, execute, maintain and terminate the agreement with you, including responding any queries from you.
The categories of personal data that will be processed for this purpose depends on the variety of services you use, but may include: name, billing and shipping address, email, phone number, payment information (including credit card numbers), content and scope of the agreement and the content of your queries.
To some extent the categories of personal data that will be processed will depend on the services you use. For example, to calculate the CO2 emission, we may process your location data during your trips, or the electronic devices data that you use at home. Such data will be asked on voluntary basis and you can amend it at any time under your profile settings.
We will process your personal data for as long as your account is active and if necessary, will retain your data for certain period of time afterwards to protect our legitimate interests (e.g. for dispute resolution) or to fulfil our legal obligation (e.g. tax and accounting law). You can erase voluntarily provided data at any time under your profile settings.
3.2. Cookies and similar tracking technologies
Cookies are text files containing small amounts of information which are sent to your browser and stored on your computer, mobile phone or other device when you visit a website. The cookies send information back to the website each time you return. You can accept/reject, manage and / or delete cookies according to your preferences.
In any case, the processing of your personal data with the help of cookies is based on your consent provided on Website’s cookie banner which you can change at any time, or based on Zerofy’s legitimate interest respective to the use of necessary cookies which allow our Website to function correctly.
The categories of personal data that will be processed for this purpose may include:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. If you need more information about cookies, visit aboutcookies.org. On this website you may find detailed, independent information on how to disable cookies through your browser preferences and how to remove cookies that are already on your computer. In order to remove cookies from your mobile phone, you should find this information in the user guide for your phone.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
We process your data to improve and optimize our Website, for example, by generating analytics about how our customers browse and interact with the Website and Mobile app, and to assess the success of our marketing and advertising campaigns. In addition we process your data to detect and prevent potential fraudulent use of our services.
We also use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Zerofy informs that you can delete all cookies stored on your computer, and in most browsers, you can set cookies not to be saved. Please be aware that if cookies are disabled, you may lose the ability to use the many features necessary to make the website work as well.
Please note that we do not alter our Website’s data collection and use practices when we detect a Do Not Track signal from your browser.
3.3. Social networks
For the purpose of managing and administering Zerofy’s social network (i.e. “Facebook” and “LinkedIn” accounts) Zerofy processes the following personal data you have provided voluntarily: your social network profile name, profile picture, public comments made on the Zerofy’s account, subject matter and text of your queries, if any.
Zerofy processes named personal data on the basis of your consent (on your request to provide you with an answer or your choice to comment) and Zerofy’s legitimate interests to communicate with our followers. Such personal data will be stored until the account of Zerofy is actively used by Zerofy unless you by yourself at any time delete your personal data earlier on.
We may delete your activity from our accounts at our own discretion if the content you have provided infringes the social media platform’s terms and conditions or Zerofy’s rights or interests. Respective to personal data processed within the social networks, you should also review the privacy notice of the respective social network platform.
3.4. Marketing Activities
Zerofy may periodically send you information that we think you may find interesting, or to ask for your help to improve our services. In particular, we may process your data to market our full range of services to you or to send you details of reports, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you. We may provide you marketing materials by email, text, push notification or phone call depending on your account or operating system settings.
The personal data processed for this purpose will be processed on the basis of your consent and / or legitimate interest of Zerofy (in case of marketing information sent to you about similar services that have already provided to you). Personal data is stored until you unsubscribe or otherwise opt-out from the marketing publications. If you unsubscribe or otherwise opt-out, the data will be deleted immediately.
3.5. Fulfilling our legal obligation
Zerofy may be obliged to process personal data when it is necessary to comply with our legal obligations which arise from the law or from the industry practice. Such data processing may be in connection with the collection of taxes or duties, bookkeeping and responding to supervisory authorities.
3.6. Service improvement and analysis
Zerofy may also process personal data to test and improve our services. To the extent possible we use anonymised data to fulfil named purpose, however there are instances where personal data processing may be required. If personal data processing is required, we have implemented appropriate organisational and technical measures to mitigate the risks that may affect individuals’ rights and freedoms e.g., personal data is pseudonymised and we have implemented access management procedure to limit the number of employees who will have access to your personal data.
For this purpose we mainly process the data collected via cookies and similar tracking technologies when you use our services.
3.7. Other purposes
Where necessary, we may process your personal data for additional purposes relating to:
- Zerofy’s legitimate interests in relation to: (i) completing transactions relating to the company (e.g. corporate restructuring, sale or disposal of assets, merger); (ii) protecting and enforcing the our rights, assets and interests, including fraud prevention.
- We may also process your personal data when you send us an enquiry or request using the contact details shown on the Website, including in relation to our services.
4. Retention of your personal data
Zerofy will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We will anonymize or dispose your personal data appropriately and securely when it is no longer required.
To determine the appropriate retention period for personal data, we will consider the following factors: (i) amount and nature of the personal data; (ii) its sensitivity; (iii) the potential risk of harm from unauthorised use or disclosure of the personal data; (iv) the purposes for which we handle your personal data; (v) whether we can achieve those purposes through other means; and (vi) applicable legal requirements.
5. Data sharing and transfer
Any information that you provide or that is collected by us, including any data collected by using cookies, may be shared with third parties (data processors) which provide us services and act on our behalf (e.g. companies providing marketing/advertising services, companies providing data centre services, IT service providers, accounting service providers, etc.). Zerofy ensures that processing of personal data by such third parties will be based on legal ground and will be performed in accordance with lawful instructions and in compliance with the applicable laws.
The personal data may also be transmitted to the relevant personal data recipients who are independent controllers. Specifically, we may share personal data with the following categories of third parties (data processors, data recipients or separate data controllers) as necessary:
- Zerofy’s group companies and our affiliate companies,
- Courier service providers,
- police, law enforcement authorities, tax authorities, other government institutions when required by law,
- our professional advisers such as lawyers, accountants,
- service providers who provide information technology and system administration services, translation, marketing, accounting, postal or courier, event management and coordination or other services,
- legal directories or other persons or entities for the purposes of obtaining feedback or references in relation to client services provided to you (if needed, we will check with you that you are willing to be contacted),
- other persons or entities if needed to provide you our services as effectively as possible.
Third countries. Zerofy will not transfer your personal data to third countries (countries outside the EU/EEA), unless this is assessed as necessary. When such transfer is necessary Zerofy will implement all the necessary measures required by law. Also, Zerofy informs that personal information collected with the help of cookie providers can be transferred to a non-EEA country (e.g. US, when Google Analytics are used). Zerofy makes every effort to ensure that such data transfers comply with the legal requirements and implements appropriate measures to ensure that your personal data remains protected and secure.
6. Data protection measures
Zerofy implements appropriate and compliant technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
We may hold your personal data in a combination of secure computer storage facilities and paper-based files. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They must only process your personal data on our instructions. They are also subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legally required to do so.
7. Your rights as a data subject
You may, at any time, exercise the following rights with respect to processing of your personal data:
- Right to access: You have the right to request access to any data that can be considered your personal data. This includes the right to be informed on whether we process your personal data, what personal data categories we process, the purpose and the legal ground that we rely on when processing your data.
- Right to rectification: You have the right to request that we correct any of your personal data if it is inaccurate or incomplete.
- Right to object: You are entitled to object to processing of personal data if the processing of your personal data is based on legitimate interest.
- Right to erasure: You may also request that your personal data be erased subject to certain statutory exceptions if the personal data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful.
- Right to data portability: If we process your personal data based on your consent or on the basis of a mutual contractual relationship, you may request that we provide you with that personal data in a structured, commonly used and machine-readable format. Moreover, you may also request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
- Right to restriction of processing. In some cases, you may have a right to request restriction of processing of your personal data or to object to processing of your personal data.
- Right to withdraw your consent: In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.
Please note that some of the rights listed above may be limited where our legitimate interests or legal obligations override your interests and rights (particularly, in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations).
We assure you that our processes are built in a way that you will not be subject to any decision based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affects you.
If you have complaints on how we process your personal data, or you would simply like to know more about our data processing activities, feel free to contact us at any time on the contact details: firstname.lastname@example.org, or zerofy OÜ, Telliskivi 60A, Tallinn, 37, 10412, Estonia.
You have the right to lodge a complaint to a Data Protection Authority if you think that your personal data is being processed incorrectly or your data subject’s rights have been violated by us. You can find contact details of the Estonian Data Protection Inspectorate here: www.aki.ee.
9. Details of the Website and ownership
The Website, content of the Website, code of the Website, design, domain name, all copyrights, trademarks, databases, corporate names and other intellectual property or other property related to the Website and / or its contents are fully owned by Zerofy and / or licensors and / or content providers, and are protected by national and international intellectual property laws and other legislation.
Unless expressly permitted by Zerofy, you have no right, in any form and by any means, to copy, capture, reproduce in any form or manner, launch, publish, transfer, sell, translate, reprocess, submit, licence, modify, create derivative works from or based upon, republish, edit, transmit, retransmit or otherwise make public, publicly perform or display, frame, distribute or use, in part or in its entirety, the Website, the Website content or Website code.
Address: Telliskivi 60A, Tallinn, 37, 10412, Estonia
Email: hello at zerofy.net