Privacy Policy

PRIVACY NOTICE – ZIP DATING LIMITED

Introduction

Thank you for reading our privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the notice https://zipconnect.app/privacy-policy.pdf. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data, including any data you may provide to us directly via our website, mobile application or otherwise.

It is important that you read this privacy notice together with any other privacy notice, fair processing notice or privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

ZiP Dating Limited is the controller and responsible for your personal data (collectively referred to as the Company, "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: ZiP Dating Limited

Email address: info@zip-dating.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 02/02/2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and application 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 website and application, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, 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 follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and photographs and videos that may identify you.
Contact Data includes billing address, home address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and application.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and your profile picture.
Usage Data includes information about how you use our website, application, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also use, store and transfer Special Category Data about you (this includes details about your race or ethnicity, information about your health and biometric data) in order to deliver our services to you with care. We do not collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial and Special Category Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- avail of our products or services;
- create an account on our website and application;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
Automated technologies or interactions. As you interact with our website and application, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
- Technical Data from the following parties:
  - analytics providers;
  - advertising networks; and
  - search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where you have given consent or explicit consent.

We rely on consent as a legal basis for processing your personal data when sending third-party direct marketing communications to you via email or text message, advertising and promoting our services to the public whether online or otherwise or, in the case of explicit consent, when processing Special Category Data in order to deliver services to you. You have the right to withdraw consent to marketing at any time by contacting us at support@zip-dating.com

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at support@zip-dating.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Type of data
To register you as a new customer/client	Identity Contact	Performance of a contract with you
To process your order or request and to deliver products/services to you including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transactional Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review, take a survey or provide other feedback	Identity Contact Profile Marketing and Communication	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers/clients use our products/services)
To enable you to partake in a competition, to complete a survey or to provide other feedback	Identity Contact Profile Usage Marketing and Communication	Performance of a contract with you Necessary for our legitimate interests (to study how customers/clients use our products/services, to develop them and grow our business)
To administer and protect our business, our website and our application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our 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) Necessary to comply with a legal obligation
To deliver relevant website and application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Market and Communication Technical	Necessary for our legitimate interests (to study how customers/clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, application, products/services, marketing, customer/client relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers/clients for our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products/services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To deliver our services to you.	Special Category Data	Performance of a contract with you. Explicit consent.
To advertise and promote our services to the public, whether online or otherwise	Identity	Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods from us or used our services if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at support@zip-dating.com

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

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 at support@zip-dating.com

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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

We 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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least six years after they cease being customers for tax purposes.

Details of other retention periods for different aspects of your personal data are contained in our retention policy which you can request from us by contacting us at support@zip-dating.com

In some circumstances you can ask us to delete your data and in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us at support@zip-dating.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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

Time limit eo respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Glossary LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at support@zip-dating.com

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data where you have given consent to the processing of your data for one or more specified purposes.

Explicit consent means processing your Special Category Data where you have given explicit consent to the processing of your Special Category Data for one or more specified purposes.

THIRD PARTIES

Internal Third Parties

Other companies in our corporate group who may act as joint controllers or processors.

External Third Parties

Service providers who may act as processors and who provide IT, email, system administration, social networking, provision and access to information and other services.
Professional advisers who may act as processors including lawyers, bankers, auditors and insurers based inside the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities who may act as processors based inside the EU who require reporting of processing activities in certain circumstances.

Transfer of your information out of the UK and EEA

We may transfer your personal information to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA) as follows:

The United States of America, in order to use our service providers who provide IT, email, system administration, social networking, provision and access to information and other services.

The USA does not have the same data protection laws as the UK and EEA. While the European Commission has not given a formal decision that the USA provides an adequate level of data protection similar to those which apply in the UK and EEA, any transfer of your personal information will be subject to a European Commission approved contract (as permitted under Article 46(5), which the Article 29 Working Party guidance confirms must be specified, of the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

If you would like further information please contact us. We will not otherwise transfer your personal data outside of the UK and EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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.

Object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.