Information Security Policy

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

2. Information About Zebek International

Zebek International’ Data Protection Officer is Oliver Poole, who can be contacted by email at info@zebek.co.uk or by post at Zebek International, 7 Holyport Rd, London SW6 6LY, United Kingdom

3. What Does This Policy Cover?

This Policy applies to all personal data that Zebek International collects, stores or processes in delivering its services or otherwise in the course of its business. As such it covers all personal data which Zebek International holds or processes about or on behalf of its clients; other users or subscribers to any of Zebek International’ services; or persons providing services to Zebek International.

4. Your Rights

As a data subject, you have the following rights, which this Policy and Zebek International’ use of personal data have been designed to uphold:

• • The right to be informed about Zebek International’ collection and use of personal data;
  • The right of access to the personal data Zebek International holds about you;
  • The right to rectification if any personal data Zebek International holds about you is inaccurate or incomplete (please contact Zebek International using the details in section 12);
  • The right to be forgotten – i.e. the right to ask Zebek International to delete any personal data Zebek International holds about you;
  • The right to restrict (i.e. prevent) the processing of your personal data;
  • The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  • The right to object to Zebek International using your personal data for particular purposes; and
  • Rights with respect to automated decision making and profiling.

If you have any cause for complaint about Zebek International’ use of your personal data, please contact Zebek International using the details provided in section 12 and Zebek International will do its best to solve the problem for you.

5. What Data Does Zebek International Collect?

The personal data which Zebek International may collect will vary depending on the nature of your interaction with Zebek International but might include some or all of the following personal and non-personal data:

• • your name;
  • the name of the organisation/charity/ business that you work for or represent;
  • the sector or cause in which your organisation operates, including any faith basis for that organisation;
  • your job title and/or profession;
  • your contact information such as email, postal address and telephone numbers;
  • demographic information about you, such as preferences, and interests;

6. How Does Zebek International Use Your Data?

All personal data shall be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. Zebek International will comply with its obligations and safeguard your rights.

Zebek International’ use of your personal data will always have a lawful basis, either because it is necessary for Zebek International performance of a contract with you, because you have consented to Zebek International use of your personal data (e.g. by subscribing to emails), or because it is in Zebek International legitimate interests. Specifically, Zebek International may (without limitation) use your data for the following purposes:

• • Supplying Zebek International products and/or services to you (please note that Zebek International requires your personal data in order to enter into a contract with you);
  • Personalising and tailoring Zebek International’ products and/or services for you;
  • Delivering services to a third party which requires the processing of your data, for example where Zebek International is undertaking a communications campaign for a client;
  • Replying to emails from you;
  • Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing info@aldgate-consulting.co.uk or clicking on the unsubscribe link within the email);
  • Market research;
  • Reporting to third parties where products and/or services have been provided to you at their cost; and
  • Procuring services from you or working with you in the course of Zebek International’ business.

With your permission and/or where permitted by law, Zebek International may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news, and offers on Zebek International’ products and services. Zebek International will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that it fully protects your rights and complies with its obligations.

You have the right to withdraw your consent to Zebek International using your personal data at any time, and to request that Zebek International deletes it.

Zebek International does not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

• • Where personal data about an Zebek International client (or a provider of services to Zebek International) has been obtained in order to deliver paid-for services, this may be retained for a period of up to 7 years following the end of the relevant contract;
  • Personal data in respect of third parties, obtained in the course of delivery of Zebek International’ services shall be retained for up to 3 years;
  • All other personal data shall be retained for up to 3 years from the date on which the purpose(s) for which it was obtained cease to apply.

7. How and Where Does Zebek International Store Your Data?

Zebek International only keeps your personal data for as long as Zebek International needs to in order to use it as described above in section 6, and/or for as long as Zebek International has your permission to keep it.

Some or all of your data may be stored outside of the Republic of Uganda. You are deemed to accept and agree to this by using Zebek International’ services or by otherwise submitting or providing information to Zebek International. If Zebek International does store data outside the Republic of Uganda, Zebek International will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the Republic of Uganda and in compliance with the applicable Republic of Uganda laws.

Zebek International has 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.

Zebek International has 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.

8. Does Zebek International Share Your Data?

Subject to the exceptions set out below (and/or elsewhere in this Policy) Zebek International will not share any of your data with any third parties for any purposes, unless you have expressly given your consent for us to do so:

9. What Happens If Zebek International’ Business Changes Hands?

Zebek International may, from time to time, expand or reduce Zebek International’ business and this may involve the sale and/or the transfer of control of all or part of Zebek International’ business. Any personal data that you have provided will, where it is relevant to any part of Zebek International’ business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use that data only for the same purposes for which it was originally collected by Zebek International.

In the event that any of your data is to be transferred in such a manner, you might not be contacted in advance and informed of the changes.

10. How Can You Control Your Data?

When you register for one of Zebek International’ services or submit personal data, you may be given options to restrict Zebek International’ use of your data. In particular, Zebek International aims to give you strong controls on Zebek International’ use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Zebek International which you may do by unsubscribing using the links provided in Zebek International’ emails).

11. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by Zebek International (where such data is held). No fee is payable and Zebek International will provide any and all information in response to your request free of charge. Please contact Zebek International for more details at info@aldgate-consulting.co.uk, or using the contact details below in section 12.

12. Contacting Zebek International

If you have any questions about this Policy, please contact Zebek International:

13. Changes to Zebek International’ Information Security Policy

Zebek International may change this Policy from time to time (for example, if the law changes). You will be deemed to have accepted the terms of the Policy on your first subsequent registration or continued use of Zebek International’ services, or interaction with Zebek International by some other means.