Part 1: Personal information and privacy
We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.
This policy (together with our website terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website, www.zaktraderscafe.com, you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998, the data controller is Miriad Limited whose registered office is at Suite 1, 15 Ingestre Place, London, England, W1F 0DU.
2. Collecting personal information
Information we collect about you.
With regard to each of your visits to our site, or use of one of our apps (including on third-party sites or platforms, or when you link your profile on a third-party site or platform with your app registration account), we may automatically collect the following information:
2.1 We may collect, store and use the following kinds of personal information:
(a) technical information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, your login information, time zone setting, browser plug in types and versions) and information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
(b) information that you provide to us when registering with our website and completing your profile on the website (including your name, email address, telephone numbers, company and job description) and includes information you provide with you participate in discussion boards or other social media functions on our website;
(c) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
(d) information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(e) information that you post to our website for publication on the internet (including your user name and the content of your posts);
(f) information contained in or relating to any communications that you send to us or send through our website messaging system (including the communication content and metadata associated with the communication); and
(g) any other personal information that you choose to send to us.
2.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this policy.
3. Using personal information
3.1 Any personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business and notify you about changes to our service and to ensure that content from our website is presented in the most effective manner for you and your computer. And including for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(b) personalise our website for you and to improve our website and allow you to participate in any interactive features of our website (if and where applicable)
(c) enable your use of the services available on our website, such as our continuing professional development monitoring service;
(d) send you non-marketing commercial communications;
(e) send you email notifications that you have specifically requested;
(f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(g) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(h) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(i) deal with enquiries and complaints made by or about you relating to our website;
(j) keep our website secure and prevent fraud; and
(k) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service);
(l) provide you, or permit selected third parties to provide you, with information about services we feel may interest you. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please contact us to let us know.
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 We may also combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. We may also disclose your personal information to analytics and search engine providers that assist us in the improvement and optimisation of our website.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law or to enforce any of our website terms or other agreements we may have with you;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling or to the seller (or prospective seller) of any business or asset that we are (or are contemplating) acquiring; and (e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information;
(f) to protect the rights, property, or safety of Miriad Limited, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. International data transfers
Any information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy and in particular may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
5.2 Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.3 By submitting your personal information, you expressly agree to the transfers, storage and processing of personal information described in this Section 5.
6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Without prejudice to Section 6.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:
(a) private message data will be deleted 7 years after creation; and
(b) account data (excluding published data and data relating to private messages sent or received on the website) will be deleted upon request or otherwise 12 months after any account deactivation.
6.4 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store any the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 Communications between logged-in users’ web browsers and our web server will be encrypted, and private messages sent through our website will be stored in encrypted form.
7.4 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page frequently to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy by email or through the private messaging system on our website.
9. Your rights
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in the following manners:
9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at £10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. Please note that if you follow a link to any of these websites, they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
11. Updating personal information
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
Part 2: Cookies
1. About cookies
1.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
1.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
1.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
1.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
2. Our cookies
2.1 We use both session and persistent cookies on our website
2.2 The cookies that we use on our website, and the purposes for which they are used, are set out below:
3. Analytics cookies
3.1 We use Google Analytics to analyse the use of our website.
3.2 Our analytics service provider generates statistical and other information about website use by means of cookies.
3.3 The analytics cookies used by our website have the following names: _utma, _utmb, _utmc and _utmz.
3.4 The information generated relating to our website is used to create reports about the use of our website.
4. Third party cookies
4.1 Our website also uses third party advertising cookies.
5. Blocking cookies
5.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
5.2 Blocking all cookies will have a negative impact upon the usability of many websites.
5.3 If you block cookies, you will not be able to use all the features on our website.
6. Deleting cookies
6.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
(b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
6.2 Deleting cookies will have a negative impact on the usability of many websites.
Part 3: Our details
1. Data protection registration
1.1 We are registered as a data controller with the UK Information Commissioner’s Office.
1.2 Our data protection registration number is ZB524576.
2. Our details
2.1 This website is owned and operated by Miriad Limited.
2.2 We are registered in England and Wales under registration number 04009984, and our registered office is at Suite 1 15 Ingestre Place, London, England, W1F 0DU.
2.3 Questions, comments and requests regarding this policy are welcomed and you can contact us in this regard by writing to the business address given above, by using our website contact form, by email or by telephone using the contact details published on the website.