This privacy policy (together with any other documents referred in it) sets out the basis for
processing any personal data we collect from you or that you provide to us.
Please read the following carefully to understand our practices regarding your personal data. By
using our website you are accepting and consenting to the practices described in this policy.
Depending on the purpose for which you are providing your personal data, for the purpose of the
Data Protection Act (the ‘Act’), the data controller (or entity responsible for the data collected) will
be either us and/or any of our subsidiaries* (together the ‘Zupa Group’). Within the context of this
policy ‘we’ means the Zupa Group.
Correspondance address:
Zupa Tech Ltd
HTEC House
George Curl Way
Southampton
Hampshire, SO18 2RX
(Registered in England: 03165847)

  1. This is a notice to inform you of our policy about all the information that we record about
    you. It sets out the conditions under which we may process any information that we collect
    from you, or that you provide to us. It covers information that could identify you (“personal
    information”) and information that could not. In the context of the law and this notice,
    “process” means collect, store, transfer, use or otherwise act on information.
  2. We regret that if there are one or more points below with which you are not happy, your
    only recourse is to leave our website immediately.
  3. We take seriously the protection of your privacy and confidentiality. We understand that all
    visitors to our website are entitled to know that their personal data will not be used for any
    purpose unintended by them, and will not accidentally fall into the hands of a third party.
  4. We undertake to preserve the confidentiality of all information you provide to us and hope
    that you reciprocate.
  5. Our policy complies with UK law accordingly implemented, including that required by the EU
    General Data Protection Regulation (GDPR).
  6. The law requires us to tell you about your rights and our obligations to you, in regards, to
    the processing and control of your personal data. We do this now, by requesting that you
    read the information provided at www.knowyourprivacyrights.org.
  7. Except as set out below, we do not share, or sell, or disclose to a third party, any information
    collected through our website.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of
your personal information and to notify you of the basis for each category.If a basis on which we process your personal information is no longer relevant, then we shall
immediately stop processing your data.
If the basis changes, then if required by law we shall notify you of the change and of any new basis
under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to
our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract, we must process the information you give
us. Some of this information may be personal information.
We may use it in order to:
• verify your identity for security purposes
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most
from using our website
We process this information on the basis there is a contract between us, or that you have requested
we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class
information, for example, to monitor our performance with respect to a particular service we
provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by
either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as
when you browse our website or ask us to provide you more information about our business,
including job opportunities and our products and services, you provide your consent to us to process
information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example,
by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to
which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not
use your information in any way that would identify you personally. We may aggregate it in a
general way and use it to provide class information, for example, to monitor the performance of a
particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and
contact information to selected associates whom we consider may provide services or products you
would find useful.We continue to process your information on this basis until you withdraw your consent, or it can be
reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at help@zupa.com. However, if you do
so, you may not be able to use our website or our services further.

Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of
doing so.
Where we process your information on this basis, we do after having given careful consideration to:
• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round,
consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
• record-keeping for the proper and necessary administration of our organisation
• responding to unsolicited communication from you to which we believe you would expect a
response
• protecting and asserting the legal rights of any party
• insuring against or obtaining professional advice that is required to manage organisational
risk
• protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

We are subject to the law like everyone else. Sometimes, we must process your information in order
to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they
have the proper authorisation such as a search warrant or court order.
This may include your personal information.

Specific uses of information you provide to us

Information provided on the understanding that it will be shared with a third party.
Our website allows you to post information with a view to that information being read, copied,
downloaded, or used by other people.
Examples include:
• Posting a message on a forum
• Uploading an image
• Uploading news ItemsIn posting personal information, it is up to you to satisfy yourself about the privacy level of every
person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third
party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our
discretion, we may agree to your request to delete personal information that you have posted. You
can make a request by contacting us at help@zupa.com.

Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years
in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the
period of your employment. This information will be used only for purposes directly relevant to your
employment. After your employment has ended, we will keep your file for seven years before
destroying or deleting it.

Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data
you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your messages, such as your name and
email address so as to be able to track our communications with you to provide a high-quality
service.

Complaining

When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to
that other person some of the information contained in your complaint. We do this as infrequently
as possible, but it is a matter for our sole discretion as to whether we do give information, and if we
do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of
service we provide, but not in a way that could identify you or any other person.

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser
when you visit any website. They allow information gathered on one web page to be stored until it is
needed for use on another, allowing a website to provide you with a personalised experience and
the website owner with statistics about how you use the website so that it can be improved.Some cookies may last for a defined period of time, such as one day or until you close your browser,
others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or
limit their use.
The Websites use cookies to distinguish you from other users. This helps us to provide you with a
good experience when you browse the Websites and also allows us to improve them. Please see our
cookie policy for further information.

Disclosure and sharing of your information

We may share your data with any member of the Zupa Group. We will not transfer any of your data
to any third parties without your permission or unless indicated in this privacy policy or agreed by
you.
We may disclose your personal information to third parties without obtaining further consent from
you including:
• to our business partners, suppliers and subcontractors for the performance of any contract
we enter into with you
• where we outsource any of our business functions under which we collect or store your
data, in which case we will ensure that any such service provider adheres to at least the
same obligations of security with regard to your data as undertaken by us
• where we sell or buy any business or assets, in which case we may disclose your personal
data to the prospective seller or buyer of such business or assets
• if we are under a duty to disclose or share your personal data in order to comply with any
legal obligation, or in order to enforce or apply our Website Terms & Conditions and other
agreements; or to protect our rights, property, or safety of our employees, our customers,
or others. This includes exchanging information with other companies and organisations for
the purposes of fraud protection and credit risk reduction.
We will never sell your data to third parties for the purposes of marketing.

Where we store your data

Our websites are hosted in the United Kingdom.
We may also use outsourced services in countries outside the United Kingdom from time to time in
other aspects of our business.
Accordingly, data obtained within the UK or any other country could be processed, transferred to,
and stored at, a destination outside of the United Kingdom. It may also be processed by staff
operating outside the UK who work for us or for one of our suppliers. Such staff may be engaged in,
among other things, the fulfilment of your order and the provision of support services. By submitting
your personal data to us, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated securely and in
accordance with this privacy policy.

Access to your own information

At any time, you may review or update personally identifiable information that we hold about you,
by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you may send us a request
at help@zupa.com.
After receiving the request, we will tell you when we expect to provide you with the information,
and whether we require any fee for providing it to you.
If you wish us to remove personally identifiable information from our website, you may contact us
at help@zupa.com. This may limit the service we can provide to you.
When we receive any request to access, edit or delete personally identifiable information we shall
first take reasonable steps to verify your identity before granting you access or otherwise taking any
action. This is important to safeguard your information.

Other Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt
any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by
looking for a closed padlock symbol or other trust marks in your browser’s URL bar or toolbar.

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as
long as required by us:
• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal
jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction,
we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.

Changes to our Privacy Policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are
those posted here on our website on the day you use our website. We advise you to print a copy for
your records.
Questions, comments and requests regarding this privacy policy are welcomed and should be
addressed to help@zupa.com
Zupa Privacy Policy
Last Modified May 2021

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