Article 110, European Electronic Communications Code

Privacy Policy

Zefonar Advisory 

Privacy Policy

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:

·  Name

  • Address
  • Company
  • Telephone number
  • Email address

·  Other data collected that could directly or indirectly identify you/your company.

Our Privacy Policy is intended to describe to you how and what data we collect, and how and why we use your personal data.  If at any time you have questions about our practices or any of your rights described below, you may contact us at  This inbox is actively monitored and managed so that we can deliver an experience that you can confidently trust.  

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.

Cookies and similar technologies on our website allow us (through GoDaddy) to track your browsing behaviour, the link clicked, your device type, and to collect various data, including analytics, about how you use and interact with our website.  This allows us to provide you with more relevant information, a better experience on our site, and to collect, analyse and improve the performance of our services.  We may also collect your location (IP address) so that we can tailor our services.  For additional information, and to learn how to manage the technologies we utilise, please visit the GoDaddy Cookie Policy.  

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)

  • Diagnose problems with and identify any security risks, errors, or needed enhancements to the services
  • Detect and prevent fraud and abuse of our services and systems
  • Collecting aggregate statistics about use of the 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:

·  Email

·  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

Transfer of personal data abroad.  If you utilise our Services from a country outside the United Kingdom, your communications with us may result in transferring your personal data across international borders.  Similarly, when you call or email us from overseas.  Nonetheless, your personal data is protected and handled according to this Privacy Policy.

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. 

Website analytics.  We use GoDaddy to run our email and web services.  That company uses multiple web analytics tools provided by service partners, such as Google Analytics, MixPanel and Singular to collect information about how you interact with our website, including what pages you visit, what site you visited prior to visiting our website, how much time you spend on each page, what operating system and web browser you use and network and IP information.  We use the information provided by these tools to improve our services.  These tools place persistent cookies in your browser to identify you as a unique user the next time you visit our website.  Each cookie cannot be used by anyone other than the service provider (ex: Google for Google Analytics).  The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which you reside. Though information collected does not include personal data, such as name, address, etc., the information collected is used and shared by these service providers in accordance with their individual privacy policies.  You can control the technologies we use by managing your settings through the Cookie Policy published by GoDaddy or the ‘cookie banners” that may be presented (depending on URL of website visited) when you first visit our webpages, or by utilising settings in your browser or third-party tools, such as Disconnect, Ghostery and others.

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.

Third-party websites.  Our website contains one link to the social media site operated by LinkedIn.  This is our only third-party link.  We are not responsible for the privacy practices or the content of third-party sites.  Please read the privacy policy of any website you visit.

Our email and web services provider is the Go Daddy Operating Company, LLC (and its related entities, including, 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  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 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

‘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

Changes in our Privacy Policy.

We (and GoDaddy) reserve the right to modify this Privacy Policy at any time.  If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.  If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

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

Contact us.

If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our services, you may contact us by email at:  

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  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.