Privacy

Zentano Privacy Statement

At Zentano our client and coaching relationship is always built on transparency, trust and confidence. Confidentiality is essential for you and us. This privacy statement provides you with the confidence that we are complying with our legal obligations.

We are committed to protecting your personal information and keeping it secure.

This notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR).

This notice applies to:

All Clients
All Third Parties and Suppliers who we deal with in our business including individuals we send marketing information.

Any reference to ‘we’, ‘us’, ‘our’, ‘the company’ means Zentano Limited.

Any reference to ‘you’ or ‘Data Subject’ means any individual receiving this notice for whom we hold personal data.

This Privacy Statement does not include information relating to retaining data for limited companies. It also applies to our website https://zentanogroup.com.

In most circumstances your data will be held by us as the “Data Controller”. This means that we are responsible for deciding how to hold and use personal information about you.

We will review this notice regularly and update it if necessary.

You must read this notice, together with any other privacy notice we may provide on specific occasions when collecting or processing personal information about you.

Data Protection Principles

We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept only if necessary for the purposes we have told you about.
Kept securely.

Client Data

Types of information we hold about clients

Personal data, or personal information, means any information about an individual from which a person can be identified. It does not include data where the identity has been removed (anonymous data).

There are “special categories” of more sensitive personal data which require a higher level of protection.

We will collect, store, and use the following categories of personal information about our clients.

Personal details including name and title
Business name and addresses
Business telephone numbers
Business email addresses
Business Skype address (if needed for Skype communications)
Summary notes for coaching sessions which only include key topics discussed and actions agreed. This will not include any personal views or judgements expressed by a Zentano coach.
Name and email address of line manager and/or business sponsor
Age (for psychometric profiling purposes only)
Gender (for psychometric profiling purposes only)

Why we hold information on clients

It is necessary for us to keep data on clients in order for us to fulfil our contractual obligations and hold data for legitimate business needs.

We will only retain data which we reasonably require and for a period which is reasonably necessary.

We will not disclose your data to the third parties unless you give us permission or we are required to do either contractually or under another law.

How we collect personal information

We collect personal information about clients directly from themselves when they contact us via telephone, email, social media or through our website.

Client and business data is stored within a GDPR compliant systems:

Microsoft Office 365
CRM system (SALPO)
MailChimp (for blog, news and marketing communications)

A mirrored copy of Zentano company data is saved on a backup device located in our Gloucester and Worcester offices using a strong, encrypted password. Data on current clients that we are actively working with may also be stored on Zentano mobile telephones we are also password encrypted. If our coaching is carried out via Skype or a similar communication application, contact data will be stored within the application for the duration that we are actively in a coaching relationship.

We reserve the right to change the systems in which data is stored without notification to another equivalent system we will make sure that your data is secure and complies with GDPR.

How we will use your information

We will only use your personal information when the law allows us to. These are the most likely circumstances in which we will use your personal information include:

To meet our contractual obligation.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these scenarios are unlikely).

The situations in which we will are likely process your personal information include:

Administering the contract I have entered into with you.
Dealing with legal disputes involving you.
To prevent fraud.
To market other products or services which I offer which may be of interest to you.
To inform you about updates about my services.
To administer my business which may include disclosure of client data to my accountant.

We will use your data to market other services to you, send you blogs, or send you news about Zentano where you have given explicit consent and you may ‘opt out’ of receiving these types of communication from me.

If you fail to provide necessary personal information

If you fail to provide certain, necessary information when requested, we may not be able to perform the contract we entered into with you or it may be prevent us from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 we need to use your personal information to meet a legal or personal/public interest obligation, if it appropriate, we will let you know and explain the basis which allows us to do so.

Non-Client Data

The kind of information we hold about individuals other than clients and how this data is used

Personal data, or personal information, means any information about an individual from which a person can be identified. It does not include data where the identity has been removed (anonymous data).

During our day to day business we may acquire information regarding individuals other than our clients and we will only retain this data where we have a legitimate business reason to do so.

Typically, we acquire personal data on individuals, third parties and suppliers other than my clients in the following circumstances:

Where we have met individuals, third parties and suppliers at networking or other marketing events;
Where individuals, third parties or suppliers have made enquiries with us regarding possible services but have not subsequently become clients of my business;
Where we have dealt with individuals, third parties or suppliers in the capacity as suppliers of goods or services to me;
Where we have regular business-related dealings with you.

We will send blogs, event details or other news relating to Zentano where you have given explicit consent. You have the option to opt out of receiving these communications.

Why might I share personal information with third parties?

I will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where I have another legitimate interest in doing so.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

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

If you communicate with us by email then you assume the risks of these being intercepted, not received or delivered, or received by individuals other than the intended recipient.

Data Retention

How long will we retain your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes I 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we can use this data freely.

We will hold client data for a period of seven years after completion of service delivery. The Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to six years after the events. We therefore have a legitimate business interest to retain the data should legal proceedings ensue.
Our clients often return for repeat within weeks, months or years of contacting us in the first instance. The seven-year period referred to above will start from the last contact we had with the client, third party or supplier. This means we can assist you as and when we need to. We will confidentially destroy all data held for you after 7 years.

Rights of Access, Correction, Erasure, and Restriction

Your duty to keep us up-to-date

It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes whilst we work together.

Your rights in connection with personal information

By law you have the right to:

Request access to your personal information (“data subject access request”). You will receive a copy of the personal information we hold about you.
Request correction of the personal information that we hold about you. We will correct any incomplete or inaccurate information we hold about you.
Request erasure of your personal information. You can ask us to delete personal information where there is no good reason for us to continue to process it. You have the right to ask me to delete your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and your situation means you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. You can ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you need to do any of the above please contact us here.

If you ask us to erase, correct, object to process or seek to restrict our processing of data we may refuse your request if we have a legal obligation, contractual or other legitimate business interest. If we refuse your request, we will let you know. You will have a right to appeal.

No fee usually required

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

What we may need from you

I may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data privacy manager

Rich Horton is the nominated Zentano Data Privacy Manager. He makes sure that we comply with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Rich here. If you want to, you can make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Cookies policy

Our website does use cookies. Our website does use data tracking including Google Analytics. If you found our website via a third-party website or search engine we can’t guarantee they won’t use Cookies, data tracking or data analytics.

Contact and further information

If you have any questions about this privacy notice or wish to submit a complaint, then please email us here. If you make a complaint then we will let you know how your complaint will be handled.