Article 110, European Electronic Communications Code
Last Revised 10 January 2019
Zefonar Advisory cares about your privacy. For this reason, through our email and web services provider, GoDaddy, and our telephone services, we collect and use personal data only as it might be needed for us to deliver to you our services. Your personal data can include information such as:
· Other data collected that could directly or indirectly identify you/your company.
What information do we collect?
We collect information so that we can provide the best possible experience when you contact us via telephone, email or through our website. Much of what you likely consider personal data is collected directly from you when you:
(1) contact us by telephone (telephone number automatically, and, manually, any contact details you provide, such as your name, organisation and email);
(2) contact us by email (email address and any contact information you provide to us in your signature box),
(3) contact us via the website (giving the contact details required in each field), or
(4) exchange information contained on your business card.
Data about website access and usage is collected automatically (by GoDaddy) when you access and interact with our website, including metadata, log files, cookie/device IDs, page load time, server response time, and approximate location information to measure website performance and improve our systems, including optimising DNS resolution, network routing and server configurations. Specifically, interactions with the features, content and links (including those of third-parties, such as the LinkedIn social media plugin) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, preferences and cookie data, information about devices accessing the website, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data is collected.
Supplemented Data If you provide us with personal information about other organisations and people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
How we utilise information.
We strongly believe in both minimising the data we collect and limiting its use and purpose to only that:
(1) for which we have been given permission,
(2) as necessary to deliver the services you request, or
(3) as we might be required or permitted for legal compliance or other lawful purposes. These uses include:
Delivering, improving, updating and enhancing the services we provide to you. We collect various items of information relating to your interactions with our website and services. We utilise these to:
· Improve and optimise the operation and performance of our services (again, including our website)
· Understand and analyse how you use our website information which is most relevant to you.
Often, much of the data collected is aggregated or statistical data about how individuals use our website and services, and is not linked to any personal data, but to the extent it is itself personal data, or is linked or linkable to personal data, we treat it accordingly.
Sharing with trusted third parties. We will not share your personal data with affiliated companies within our corporate family without your agreement. When we do so, it will be for purposes such as:
· Performing analysis of our services and customers
· Communicating with you, such as by email or telephone as requested, and
· Customer relationship management.
We only share your personal data as necessary for any third party to provide the services you requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any purpose other than as they have been specifically contracted for (or without your consent).
Communicating with you. Unless you specifically request us not to do so, we will only contact you directly in response to a request from you or to maintain a client relationship (actual or potential). These contacts may include:
· Text (SMS) messages
· Telephone calls.
You may also update your preferences with respect to receiving or terminating future communications from us by sending an email to firstname.lastname@example.org.
Compliance with legal, regulatory and law enforcement requests. We cooperate with government and law enforcement officials and authorised private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests), to protect our property and rights or the property and rights of a third party, to protect the safety of the public or any person, or to prevent or stop activity we consider to be illegal or unethical.
To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.
Targeted advertisements. It is our policy not to send you targeted advertisements, nor will we share your personal data with third parties to enable them to do so.
Our email and web services provider is the Go Daddy Operating Company, LLC (and its related entities, including GoDaddy.com, LLC, Blue Razor Domains, LLC, Starfield Technologies, LLC, Domains by Proxy, LLC, Outright, Inc., Mad Mimi, Inc. and Media Temple, Inc.). The company participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Framework. Go Daddy Operating Company, LLC is committed to subjecting all personal data received from the EU or Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Go Daddy Operating Company, LLC is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Go Daddy Operating Company, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to each Privacy Shield Framework, Go Daddy Operating Company, LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Go Daddy Operating Company, LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that GoDaddy has not addressed satisfactorily, please contact their U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
How you can update or delete your data.
Please email us at email@example.com to update or delete any data that you have provided to us previously.
How we secure, store and retain your data.
We follow generally accepted standards to store and protect the personal data we collect, both during transmission and once received and stored, including utilisation of encryption where appropriate.
We retain personal data only for as long as necessary to provide the services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods:
· mandated by law, contract or similar obligations applicable to our business operations;
· for preserving, resolving, defending or enforcing our legal/contractual rights; or
· needed to maintain adequate and accurate business and financial records.
If you have any questions about the security or retention of your personal data, you can contact us at firstname.lastname@example.org.
‘Do Not Track’ notifications.
Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, GoDaddy does not currently alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.
Data Protection Authority.
If you are a resident of the European Economic Area (EEA), we will maintain your personal data subject to the General Data Protection Regulation (GDPR). You may direct questions or complaints to your local supervisory authority or our lead supervisory authority, which is the UK's Information Commissioner’s Office, as noted below:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Phone: +44 (0)303 123 1113
If you have any issues with our email and web services provider, please contact the GoDaddy Office of the Data Protection Officer by email at email@example.com. Alternatively, you may contact them by either of the following means:
· By Mail: Attn: Office of the Data Protection Officer, 14455 North Hayden Road, Suite 219, Scottsdale, AZ 85260 USA, or
· for customers established in the EEA, Attn: Legal, Office of the DPO, 5th Floor, The Shipping Building, Old Vinyl Factory, 252-254 Blyth Road, Hayes, UB3 1HA, United Kingdom, or
· By Phone: +44 (0)20 7979 2661.
We will respond to all requests, enquiries or concerns within thirty days.