Welcome to Zenbundle Limited Limited’s Privacy and Data Protection Policy (“Privacy Policy”).Updated 27/03/24

1.1 INTRODUCTION

Important information and who we are
‍
At Zenbundle Limited Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the General Data Protection Regulation (“GDPR”) laws.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

Customers
Suppliers
Business contacts
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Zenbundle Limited Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to support@zenbundle.com or by post to Coliemore House, Coliemore Road, Dublin, A96 A8D5, Ireland.

You have the right to make a complaint at any time to the Data Protection Commissioner (DPO), the Republic of Ireland supervisory authority for data protection issues (https://www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”).

The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);

Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;

Obtain the prior specific or general authorisation of the Controller before engaging another Processor;

Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;

Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;

Maintain a record of all categories of processing activities carried out on behalf of a Controller;

Cooperate, on request, with the supervisory authority in the performance of its tasks;

Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;

and

Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
‍Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
‍Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
‍Access Data: This type of service allows the Zenbundle Application to access Data from your account on a third-party service such as Google Analytics to analyze web traffic and user behaviour. Zenbundle's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited User requirements.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
‍Financial Data: These are your banking details e.g. your account number and sort code.
‍Transactional Data: This is information of details and records of all payments you have made for our services or products.

We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
‍“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
‍“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
‍“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
‍“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity	Type of data	Legal Justification	Lawful basis for processing data
User visiting the public website for the first time	Technical Data Usage Data	Legitimate Interest	We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services.
A User requesting and attending a live demo of our products/services or inquiring into our services through a call with members of our sales/support team.	Profile/Identity Data Contact Data	Consent	Certain company information will be taken at this time, including names and position of the contact requesting the demo, further information or sales call.
User signing up to the platform and creating an account	Profile/Identity Data Contact Data Marketing and Communications Data Transactional Data Technical Data Usage Data	Consent Contractual Obligations Legitimate Interest	(a) Consent You will need to include Personal Data when filling in the Company profile on the platform so the content you create is linked to your profile. (b) Contractual Obligation In order to use our Platform you need to contract with us under our Terms of Service and so this data is necessary to form the contract between us. (c) Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services.
User makes makes a purchase on the Website	Profile/Identity Data Contact Data Billing Data Financial Data Transactional Data	Consent Contractual Obligations Legitimate Interest	(a) Consent You will need to include Personal Data when filling in the Company profile on the Platform so the content you create is linked to your profile We will retain the name that is stated on the credit/debit card you enter into our Stripe API but all other card details are stored by them and not retained by us (b) Contractual Obligation In order to use our Platform you need to contract with us under our Terms of Service and so this is necessary to form the contract between us We need to retain your Transactional Data so that we can comply with our legal obligation to send you an invoice following a purchase (c) Legitimate Interest We need to know who you are so that we know who to deliver the service to once it has been purchased. It also enables us to provide support to the right individual in case there is an issue with the purchased product
User support with specific products	Profile/Identity Data Transactional Data Customer Support Data Usage Data	Consent Legitimate Interest	(a) Consent We may need your telephone number or other further contact details if reaching out to you is best achieved via those details instead of our live chat (b) Legitimate Interest We will retain records of the transactions you have made with us and what you have used on the Platform so when you come to us with an issue we can quickly identify what your issue relates to and provide you with the most efficient support
To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.	Profile/Identity Data Contact Data Technical Data	Contractual Obligations Legitimate Interest	(a) Legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Contractual Obligation To be able to comply with all legal obligations surrounding data collection, processing and retention.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.	Technical Data Usage Data	Legitimate Interest	a) Legitimate interest To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy
To use Google Analytics data to help with our retail media estimatation.	Profile/Identity Data Transactional Data Usage Data	Consent Legitimate Interest	a) Legitimate Interest We need to know user and traffic performance data so that can provide an estimate of the potential retail media revenue that your website could possibly generate.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
‍Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.

‍Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.4 below for more details on how you can make a data subject access request.

Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
    Where we are processing your personal data for direct marketing purposes.
    Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
    In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
    If you want us to establish the data's accuracy.
    Where our use of the data is unlawful but you do not want us to erase it.
    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at support@zenbundle.com.

4.2 How Zenbundle Limited protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including Our admin web pages, along with our data processing systems, are protected with strong password credentials and accessible exclusively through Virtual Private Network (VPN) or Secure Shell Protocol (SSH). All data transmitted between systems or over networks and all data stored at rest are encrypted using industry-standard encryption protocols. Our data processing activities are hosted on Amazon Web Services (AWS), a secure and compliant cloud platform. AWS provides robust security features, including encryption for data in transit (using protocols like TLS/SSL) and data at rest (using services like AWS Key Management Service).

Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.

However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Zenbundle Limited Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing messages at any time by emailing support@zenbundle.com.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

5. YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors or affiliates, subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions.

We may also share Personal Data with interested parties in the event that Zenbundle Limited Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Zenbundle Limited Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

5.2 Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

6. HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

You must not use Zenbundle Limited Limited unless you are aged 18 or older. If you are under 18 and you access Zenbundle Limited Limited by lying about your age, you must immediately stop using Zenbundle Limited Limited.

This website is not intended for children and we do not knowingly collect data relating to children.

8. INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Zenbundle Limited Limited has facilities. By using Zenbundle Limited Limited, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here. This version is dated 27 March 2024.

By using Zenbundle Limited Limited, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Zenbundle Limited Limited will constitute your express acceptance of any modifications to this Privacy Policy.

10. INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of Zenbundle Limited Limited, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Zenbundle Limited Limited address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Zenbundle Limited Limited rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Zenbundle Limited Limited legal department.

11. TERMS OF USE

Please also see our Terms of Use (https://www.zenbundle.com/website-terms-of-use) which set out the terms, disclaimers, and limitations of liability governing your use of Zenbundle Limited Limited.