DATA SECURITY FOR DIGITAL MARKETING

We know how critical data security is these days. Zymplify’s platform is hosted by a UK based data-centre. The Zymplify application is protected by a firewall and data exchanged between yourselves and the application is encrypted in transit.

We utilise the services of an independent third-party professional certification company to perform penetration testing, to validate our data security policies and practices. See below for more details.


Data Protection Policy :

1. Introduction

This Policy sets out the obligations of Zymplify Limited a company registered in Northern Ireland under number NI068866 whose registered office is at 27/28 The Promenade, Portstewart, BT55 7AE (“the Company”) regarding data protection and the rights of customers, business contacts and website visitors (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

 

    2. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

 

    3. The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

 

    4. Lawful, Fair, and Transparent Data Processing

    • The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
      • The data subject has given consent to the processing of their personal data for one or more specific purposes;
      • The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
      • The processing is necessary for compliance with a legal obligation to which the data controller is subject;
      • The processing is necessary to protect the vital interests of the data subject or of another natural person;
      • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
      • The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

5. Specified, Explicit, and Legitimate Purposes

6. Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

7. Accuracy of Data and Keeping Data Up-to-Date

8. Data Retention

9. Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10. Accountability and Record-Keeping

11. Data Protection Impact Assessments

12. Keeping Data Subjects Informed

13. Data Subject Access

14. Rectification of Personal Data

15. Erasure of Personal Data

16. Restriction of Personal Data Processing

17. Objections to Personal Data Processing

18. Automated Decision-Making

19. Profiling

20. Personal Data Collected, Held, and Processed

 Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

 

Data Ref.

Type of Data

Purpose of Data

001

Name

Identification

002

Email Address

To send email communications

003

Telephone Number

For telephone communications

004

Social media handles

To interact with customers and prospects on social media

005

IP Address

For tracking website visitors and analytics

21. Data Security - Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

22. Data Security - Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

23. Data Security - Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

24. Data Security - Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

25. Data Security - IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

26. Data Security - Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

27. Transferring Personal Data to a Country Outside the EEA

28. Data Breach Notification

29. Implementation of Policy

This Policy shall be deemed effective as of 21st May 2018 No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

 

This Policy has been approved and authorised by:

Name:

Michael Green

Position:

VP, Finance & Data

Date:

21st May 2018

Due for Review by:

21st May 2019

Signature:

Michaelg