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Privacy Policy

Purpose
This Privacy Policy describes how Zunoma Ltd (“Zunoma”) collects, uses, stores, shares, and protects personal data processed through its website and associated digital services.

Scope
This Policy applies to all visitors to Zunoma’s website, individuals submitting data online, and all systems that process such data.

Definitions
Personal Data: Information relating to an identified or identifiable person.
Processing: Any operation performed on personal data.
Controller: Zunoma Ltd.
Processor: Third parties acting on Zunoma’s behalf.
Data Subject: The identified or identifiable individual to whom personal data relates.

Information We Collect
Personal Information: name, email, organisation, contact details.
Usage Data: IP address, browser type, device info, timestamps, pages visited.
Cookies and Similar Technologies: We use cookies to support website functionality, performance, analytics, and security.

Source of Personal Data Collected via Third-Party Technologies
In addition to data you provide directly, we receive certain usage and behavioural data from third-party technologies integrated into our website. Where this data constitutes personal data, we are required by Article 14 UK GDPR to disclose its source. The relevant third-party providers and the data they supply are as follows:

  • Google Analytics 4 (Google LLC, USA) – anonymised IP address, unique visitor identifiers, session data, page views, timestamps, and engagement metrics. IP addresses are truncated before storage, and the data is aggregated for statistical analysis. Google acts as our data processor.
  • HubSpot, Inc. (USA) – visitor tracking tokens, session timestamps, and pageview data used to understand visitor behaviour and, where consent has been given for marketing cookies, to track contacts across visits and deduplicate records in our CRM. HubSpot acts as our data processor.
  • StatCounter (Ireland) – unique visitor identification data used to understand how many distinct visitors view our site. StatCounter acts as our data processor.
  • Cloudflare, Inc. (USA) – device and connection information including IP address, processed for security, bot detection, and content delivery. Cloudflare acts as our data processor.

Google LLC, HubSpot Inc., and Cloudflare Inc. are based in the United States. Transfers of personal data to these providers are protected by Standard Contractual Clauses approved by the ICO. Full details of each provider’s data practices, and your options to opt out of non-essential tracking, are set out in our Cookie Notice.

Cookies and Similar Technologies
We use cookies and similar technologies on our website to support functionality, enhance performance, improve user experience, and help us understand how visitors interact with our site. Non-essential cookies are only used with your consent, in accordance with Regulation 6 of the Privacy and Electronic Communications Regulations (PECR), as amended by the Data (Use and Access) Act 2025, and the UK GDPR.

Cookie consent is managed through our CookieYes consent platform, which allows you to accept, reject, or customise your preferences at any time. You can change your cookie settings at any point by selecting “Cookie Settings” in the footer of our website.

Details of the cookies we use—including categories, purposes, retention periods, lawful bases, third-party technologies, and your rights—are set out in our separate Cookie Notice, available on our website.

Lawful Bases for Processing
We rely on the following lawful bases, depending on the nature of the processing activity:

  • Contractual Necessity – processing your contact details to respond to enquiries and fulfil service requests.
  • Consent – sending marketing or product updates where you have opted in; placing non-essential cookies.
  • Legitimate Interests – maintaining and improving the security and performance of our website and systems; protecting against fraud.
  • Legal Obligation – retaining records required by law and responding to lawful requests from regulators or authorities.

How We Use Personal Information
We may use personal information to:

  • Respond to enquiries and requests for information.
  • Establish and sustain commercial relationships.
  • Provide products, services, and information you request.
  • Send product or service updates where you have consented to receive them.
  • Maintain and improve the security and performance of our website and systems.
  • Protect our rights, property, and safety, and that of others.
  • Comply with legal and regulatory obligations.

How We Share Your Information
We may share your personal data with the following categories of recipient: approved third-party processors providing hosting, analytics, CRM, consent management, and security services; regulators, law enforcement agencies, and other authorities where we are required to do so by law or to protect our legal rights. We do not sell your personal data. A list of our current processors is available on request by contacting our Data Protection Officer.

International Transfers
Certain processing may involve transfers outside the UK. Safeguards include ICO-approved Standard Contractual Clauses.

Data Retention
We retain personal data only as long as necessary for the purposes described in this Policy. Website-collected personal data is retained in accordance with legal requirements and Zunoma’s retention rules.

Specific retention periods for each category of personal data collected through this website are set out in our Data Retention Policy, which is available on request. Where data is no longer required, it is securely deleted or anonymised in accordance with that policy.

Your Rights
Under UK GDPR, you have the following rights in relation to your personal data:

  • Right of access – to obtain a copy of your personal data and information about how it is processed.
  • Right to rectification – to have inaccurate data corrected or incomplete data completed.
  • Right to erasure – to request deletion of your personal data where there is no compelling reason for its continued processing.
  • Right to restriction – to request that we limit processing of your data in certain circumstances.
  • Right to object – to object to processing based on legitimate interests or for direct marketing purposes.
  • Right to data portability – to receive your data in a structured, commonly used format where processing is based on consent or contract.
  • Right to withdraw consent – at any time where processing is based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our Data Protection Officer using the details in the Contact Us section below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.

Security
Our security measures are aligned with ISO 27001:2022 and include encryption, access controls, monitoring, classification, and incident response.

Automated Decision-Making
We do not engage in automated decision-making producing legal or significant effects.

Changes to This Privacy Policy
This Policy is reviewed annually, or sooner if legal, regulatory, or operational changes occur. The current version is always available on our website.

Contact Us
Data Protection Officer
Zunoma Ltd
45 Brampton Road
Eastbourne
BN22 9AH

Email: dataprotectionofficer@zunoma.com

The Data Protection Officer named above is a voluntary designation. Zunoma takes data protection seriously and the DPO is responsible for overseeing compliance with this Policy and UK GDPR.

If you are not satisfied with our response to a complaint, you have the right to complain to the Information Commissioner’s Office (ICO): www.ico.org.uk | 0303 123 1113.