// Privacy Policy Effective date: 17th OCTOBER, 2024
Overview
The following Privacy Policy shall govern the lawful, fair and transparent processing of Personal Data of natural persons conducted by Zero X Fourteen LTD, Society Barn The Street, Assington, Sudbury, England, CO10 5LW, UK as the operator of the Zero X Fourteen Website . Relevant persons pursuant to the Regulation EU 2016/679 of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, or „GDPR“):
1. The Data Controller is Zero X Fourteen LTD Society Barn The Street, Assington, Sudbury, England, CO10 5LW, UK (hereafter: the „Controller“ or “Zero X Fourteen LTD” or “we” or “our” or “us”);
In line with the GDPR, we are updating our Privacy Policy so you can better understand why and how we collect, process and erase your data. We are committed to protecting and respecting your privacy. This Policy sets out the legal basis on which any Personal Data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
This Privacy Policy shall describe
– the type of Personal Data we collect
– the legal basis and legal requirements for Personal Data collection,
– the scope, purpose and method of Personal Data collection,
– the security measures to be undertaken to protect any and all collected Personal Data,
– Personal Data management rights,
– the time limit (duration) of storage of collected Personal Data.
What personal data we collect?
We collect Personal Data of natural persons using our website (herein after: “Users” or “You”) and Personal Data of natural persons as representatives or employees of our Clients.
NOTE: We will inform you if providing some Personal Data is optional, including if we ask for your consent to process it.
We collect Personal Data when:
1. a User contacts us as an employee or representative of a Client or prospective Client of Zero X Fourteen LTD;
2. we execute additional AML/KYC reviews of Clients or prospective Clients;
3. a User browses our website;
1. Personal Data we collect when you contact us as an employee or representative of a Client or prospective Client of Zero X Fourteen LTD:
i) First name
ii) Last name
iii) E-mail address
iv) Position within company
v) Phone number (optional)
What do we use this Personal Data for?
Zero X Fourteen LTD exclusively enters into agreements to provide products and services with companies – telecommunication services providers (“Clients”). We process the above information to enable you, as an employee or representative of a Client to initiate entering into a business relationship with Zero X Fourteen LTD. These Personal Data may, with your consent, also be used to promote Zero X Fourteen LTD products and services.
2. Personal Data we collect when we execute additional KYC reviews of Clients or prospective Clients;
i) First name
ii) Last name
iii) E-mail address
iv) Position within company
v) Phone number
vi) Company name
vii) Company address
viii) Company city
ix) Company country
x) Company registration number
xi) Company VAT number (optional)
xii) Company ZIP number (optional)
What do we use this Personal Data for?
Certain Zero X Fourteen LTD products and services are designated as dual-use items and are subject to export controls. Export control for dual-use items consists of a robust KYC procedure to determine the end-user (the Client) and legal representatives and ultimate beneficial owners of the Client, as well as the Client’s intended use of products and services.
3. Personal Data we collect when you browse the Zero X Fourteen website
i) your IP address through the placement of cookies; and
ii) location data, which might be gained through your IP address or GPS data
This is information we collect by placing cookies on your devices, following your consent pursuant to our Cookie Policy.
What do we use this Personal Data for?
This is the information we collect while you browse our Website, mainly to improve our service. Read our Cookie Policy to find out more.
HOW WE USE YOUR PERSONAL DATA
We use the Personal Data you provide about yourself to provide our products and services i.e. to enter into an agreement with our end users. We may use or disclose Your information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. If we consider it necessary, we may disclose your Personal Data to third parties in good faith that such disclosure is reasonably necessary to (i) take action regarding suspected illegal activities; (ii) investigate, enforce or apply our End User License Agreements or this Privacy Policy; (iii) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (iv) protect our rights, reputation, or property or that of our Users, affiliates, the public or other third parties. Please note that we are not required to question or contest the validity of any search warrant, subpoena, or other similar governmental request we may receive. We use information about which links have been followed and whether action has been taken on another party’s website in order to improve our offerings. Technical and navigational information, such as computer browser type, IP address, pages visited, and average time spent on the Zero X Fourteen Website, may be used, for example, to alert you to software compatibility issues, or it may be analysed to improve our website design and functionality.
LEGAL BASIS FOR PROCCESING OF PERSONAL DATA
The legal basis for processing of Personal Data:
a) Processing is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the User prior to entering into a contract;
The processed Personal Data specified under II.1. and II.2 is necessary to enable us to enter into an agreement with a Client, to execute such agreements and provide our products and services pursuant to our EULA.
b) processing is necessary for compliance with a legal obligation to which the Controller is subject;
We must process and store certain Personal Data specified under II.1. and II.2. because we are legally obligated to allow the User to exercise his or her rights under the GDPR.
c) processing is necessary for the purposes of the legitimate interests pursued by the Controller;
We collect Your Personal Data under II.1. and II.2. for the following legitimate interests:
• Maintenance of records of communications and management of Client relationship with us;
• To comply with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, anti-money laundering and anticorruption);
• Prevention and detection of fraud and other illegal activity or misconduct;
• For informing you about compliance with legal and regulatory obligations and to provide related guidance.
d) the User has given consent to the processing of his or her Personal Data for one or more specific purposes;
Usually, this is the case when you request us to disclose your Personal Data to other people or organizations, or otherwise agree to disclosures.
This is also the case when we ask to collect your Personal Data while you browse our Website, all in accordance with our Cookie Policy.
This is also the case with all Personal Data we collect and process for promotional and marketing purposes.
DURATION OF RETENTION OF PERSONAL DATA:
We retain your Personal Data to protect our legitimate business interests and to meet legal obligations for a minimal period required by law. In any case, we will retain your Personal data for at least 5 years. Personal Data collected exclusively for promotional purposes shall be retained for no shorter than 1 year after such Personal Data processing consent is given. After this period has passed your Personal Data will be automatically deleted, or/and deleted per your request.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may share your Personal Data with the following types of recipients:
a) With companies within our business group, sub-contractors, third-party service providers and partners who provide data processing services to us, such as legal and financial advisory services, IT-support, etc. All such parties are obligated to use your Personal Data in accordance with this Privacy Policy and our EULA.
b) With any competent law enforcement body, regulatory authority, government agency, court of law or other third party where we believe disclosure is necessary
(i) as a matter of applicable law or regulation,
(ii) to exercise, establish or defend our legal rights, or
(iii) to protect your vital interests or those of any other person.
c) With a potential or actual buyer (and its agents and advisers) in connection with any proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information solely for the purposes disclosed in this Privacy Policy.
d) With any other person with your consent for such disclosure.
WHAT ARE YOUR DATA PROTECTION RIGHTS?
You have the following data protection rights:
(a) To access, correct, update or request deletion of your personal information. You may do so by contacting us using the information in the “How To Contact Us” section below.
(b) To object to the processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict processing of your personal information or request portability of your personal information. Again, you may do so by contacting us using the information in the “How To Contact Us” section below.
(c) To opt out of marketing communications we send you, at any time. You can exercise this right by clicking on the “unsubscribe/opt out” link in the marketing communications we send you or by contacting us using the information in the “How To Contact Us” section below.
(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us using the details in the “How To Contact Us” section below.
(e) You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
AUTOMATED DATA PROCESSING
We do not use automated data processing (automated decision making).
TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES
A network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers supports our operations. We and our third-party service providers store and process your Personal Data in the European Union. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries.
CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, in accordance with the significance of the changes we make. The revised Privacy Policy will be effective as of the published effective date.
CONTACT US
You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account information or Personal Data.
e-mail: 401 @zero-x14.io