This Policy covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, apps, third-party social networks, points of sales and events. Please note that We combine Personal Data that We collect via one method (e.g. the Website) with Personal Data that We collect via another method (e.g. Zota’s offline event).
Whilst carrying Processing Activities (as defined in the GDPR), Personal Data may be processed by other companies which are part of Zota Group.
Our Commitment to You
At Zota, we treat all individual visitors that enter our Website, as well as all private individuals that represent our corporate clients and all our private individual clients as Data subjects in the sense of the UK GDPR. Zota fulfils the role of the Data Controller with regards to all personal data, which relates to all individual visitors that enter our corporate website, as well as to all individual persons that represent our corporate clients (i.e. representative/s, local management and Universal Beneficial Owner/s).
Zota has appointed a Data Protection Officer (DPO). This DPO remains independent within our corporate structure and has a direct connection to the top-level management at Zota by submission of electronic correspondence to [email protected], you can get in touch with our DPO and submit your request with regards to your personal information.
We understand the importance of maintaining the confidentiality and privacy of your personal information and data. By entrusting us with your information and data, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of your information and data.
What Data do we at Zota collect?
Zota collects personal information from the chat function on our Website, by the IT infrastructure of our Website provided by our website’s server host, via the use of our contact form in the ‘contact us’ section of our corporate website by individual visitors of our Website and during the course of rendering our services to You (our clients). This information collected include, but is not limited to the following data:
From corporate clients
- Certificate of incorporation
- Certificate of shareholders
- Certificate of registered address
- Resolution of Directors
- Certificate of Incumbency
- Certificate of good standing
- Memorandum and Articles of Association
- Audited financial statements
- Copies of Licenses granted to the corporate entity
- Information on corporate bank account numbers
- Set of contact data of corporate entity
- Set of contact data of employees and / or local management and / or Universal beneficial Owner
From individuals representing a corporate client
- Copy of Passport
- Copy of ID card
- Proof of physical address of an individual
- Information and documents related to an individual’s profession and /or employment
- Criminal record of an individual
- Documents on the financial status of an individual (e.g. non-bankruptcy certificate)
- Professional certificates of an individual’s professional background
- Documents regarding the educational background of an individual
- Documents related to the origin of wealth of an individual
- Contact telephone number(s) related to an individual
- Electronic mail address related to an individual
What is your personal data used for?
Log Data, which is collected via our IT infrastructure for our corporate Website, www.zota.com, and which includes the IP (Internet Protocol) address and geographical location, as well as the internet access service provider of an individual visitor, information of the type of computer or telecommunication device used to enter our corporate website, information on the data accessed, the duration and frequency of sessions and the page visit history is used for internal statistical purpose only and neither retained, nor disclosed to any third party.
Contact data, including an individual’s name, surname, electronic mail address and any other personal information communicated to Zota via our chat function on our Website, as well as via the contact form in the ‘contact-us’-section of our corporate website, is used only for establishing a proper communication channel with the specific data subject. This data is stored and retained in accordance with the applicable legislation and neither disclosed to any third party, nor accessible to any unauthorized personnel or third party.
All data collected by Zota, which relate to our prospective and / or existing client (including individuals as well as representative/s, UBO/s and / or local management of corporate clients) is used for rendering our services to our clients.
Personal data related to a specific individual data subject is used to send commercial and non-commercial notifications of Zota to that data subject.
The sources of personal data
The Personal Data that We collect mostly directly from you and include the following sources:
Website. From Your use of the Website.
E-mail, text and other electronic messages. Electronic communications between you and Us.
Points of Sales. Demonstrators present in third-party physical stores to assist you with the registering of Your ordering.
Data from other sources. Third party social networks (e.g. such as Facebook, Google, Twitter, YouTube) or market researchers (if feedback not provided on an anonymous basis).
How is your personal data stored and/or retained?
Zota will only use, store, process and handle the client’s Personal Information and Data, in accordance UK GDPR.
This means we retain hard copies of personal data related to individual persons (individual visitors of our corporate website, private clients and/or representative/s or UBO/s of corporate clients) in protected storage facilities, to which unauthorized persons do not have any access.
We retain electronic soft copies of personal data related to individual persons (individual visitors of our corporate website, private clients and/or representative/s or UBO/s of corporate clients) in protected and encrypted IT facilities, free from unauthorized access.
All communication in which individuals share their personal data with Zota, the communication channel is protected by a SSL secure log protocol technology.
Without derogating from the above, access to Your information is limited and covered by internal etiquette policies and procedures, designed to safeguard the information from loss, misuse and improper disclosure.
Your Rights to your data
In line with the provisions and requirements of the UK GDPR on the protection of personal data, you remain the following rights to your personal data:
- You remain the right to have done corrections, rectifications and refreshments to your personal data.
- You remain the right to have your personal data deleted partly or completely.
- You remain the right to obtain information on the use and purpose to process your personal data.
- You remain the right to limit the purpose for processing and use of your personal data. However, this may have an effect on the accessibility of our regulated financial services rendered to you. You can refer to our DPO and / or our Compliance Department for further clarifications on this.
- You remain the right to opt-out from commercial and non-commercial newsletters and notifications from Zota by notification to our DPO accordingly.
- You remain the right to have all personal data, which is related to you, and which is or had been collected during your visit and use of our corporate website and during your correspondence with Zota, being transferred to another Data Controller nominated by you.
- You remain the right to withdraw your previously given explicit consent with regards to the collection, use and processing of your personal data at any time by contacting our Data Protection Officer by electronic mail services to [email protected].
You can submit your request to make use of the above rights to your personal data by contacting our Data Protection Officer (DPO) through electronic mail services to [email protected].
We will not without your consent disclose to third parties any individually identifying information, such as names, postal and e-mail addresses, telephone numbers, or other, which you have provided to Zota.
The rendering of our services to our company’s prospective and / or existing clients requires the disclosure of personal data related to our prospective and / or existing clients to third parties. These third parties are external service providers, which are legally and economically independent from Zota and have third party agreements in place with Zota, whereas all of our subcontractors and / or external service partners are bound to our standard on Data Protection. Prior to processing personal data related to our clients, Zota will inform the specific client about that use and asks for the explicit consent of that person accordingly.
We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website [Terms and Conditions[hyperlink]]. Furthermore, your personal data is permitted to be disclosed to public bodies only in cases where the disclosure concerns matters of national and/or international security, the prevention or investigation of criminal activities, law enforcement, where a public interest is given, a juridical proceeding against the person, to which the personal data is related is pending or had been initiated or completed before and/or the personal security of the individual to which the personal data is related.
The data collected is read out from the cookie file by and retained on the website server / host in electronic form. The purpose for collecting this data is to identify a specific individual visitor after entering our corporate website. This data related to the individual visitor of our corporate website may be used by Zota for internal statistical and analytical purpose only.
You can deactivate the use of cookie files by effecting the modifications in the system settings of the browser application you use for entering our corporate website. Please refer to the help documents and / or technical support for the browser application used for the entering of our corporate website accordingly. By selecting to empty the cache folder of your browser application and by deleting the browser history, cookie files can be deleted completely or partly.
Web beacons (also known as “web bugs”) are small strings of code that deliver a graphic image on a web page or in an email for the purpose of transferring data back to Us. The information collected via web beacons will include information such as IP Address, as well as information about how you respond to an email campaign (e.g. at what time the email was opened, which links you click on in the email, etc.). We will use web beacons on Our Website or include them in e-mails that We send to you. We use web beacon information for a variety of purposes, including but not limited to, site traffic reporting, unique visitor counts, advertising, email auditing and reporting, and personalization.
We are not responsible for events beyond our direct control. We cannot guarantee nor do we represent that there will be error-free performance regarding the privacy of the Information, and we will not be liable for any direct, indirect, incidental, consequential or punitive damages relating to the use or release of the Information.
If you feel your personal data has been infringed by Zota, please get in touch with our DPO at [email protected].
[Last updated on August 2023]