Last updated in July 2020
If you have questions on how we collect, store and use your personal data or if you would like to exercise any of your data protection rights described under Section 11 below, please email us here
The personal data we collect about you broadly falls into the following categories:
|Types of personal data||Why we collect them|
|Information you voluntarily provide to us:
· Contact details; e-mail address, other information you send us
|When you contact us via e-mail, we collect these data (as well as other information you may send us via e-mail) to process your inquiry.|
|Information we automatically collect when you visit our Website (log file data):
· Browser type and version
· Operating system
· Referrer URL (website from which you access our site)
· Tillotts URLs that you access
· Date and time of access
· Internet Protocol (IP) address
|The log file data are automatically provided by your web browser. In certain countries, including the countries in the European Economic Area, this information may be considered personal data under applicable data protection laws. We use this information to understand how our Website is used, where our website visitors come from and what content on our Website is of interest to our visitors. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website for our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under Section 6 below.
If we ask you to provide additional personal data not already described above, we will inform you about the intended purpose at the time of collection.
We may disclose your personal data to the following categories of recipients:
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only (i) where we need the personal data to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person. If we ask you to provide personal data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Website and for our legitimate commercial interest, for instance, when responding to your queries or to improve our Website. We may have other legitimate interests and if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions on the legal basis for the collection and use of your personal data or require further information, please get in touch using the contact details provided in Section 2 above.
Our Website uses Google Analytics, a web analysis service by Google Ireland Limited, Gordon House, bArrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses text files which are stored on your computer and enable us to analyse how you use our website. The information generated by the Google Analytics Cookie about the use of the website is generally transferred to a Google server in the USA and stored there. On this website, Google Analytics has been supplemented by the code “gat._anonymizeIp();” in order to guarantee anonymised collection of IP addresses (called IP masking). This serves to shorten your IP address in advance by Google within the EU/ European Economic Area.
Only in exceptional cases is the complete IP address transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of the Website, compile reports about website activities for the website operators and perform other services associated with the use of websites and the Internet.
The IP address transmitted by your browser as part of Google Analytics is not linked to any other data stored by Google.
Google LLC including its subsidiaries is EU-US Private Shield certified. For more information, please see the following US government link:
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
Your personal data may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of your country of residence.
Our servers are located in Switzerland, a country that that the European Commission has decided provides an adequate level of data protection, and our parent company and some of our third party service providers and partners operate in countries like Japan and the USA. This means that when we collect your personal data, we may process it in any of these countries.
In cases where your personal data is transferred to a country outside the EU/European Economic Area (“EEA”) which is not covered by a decision of the European Commission that the country concerned ensures an adequate level of protection, we will take such measures as are necessary to ensure the transfer is in compliance with the applicable data protection laws, including the GDPR. Such measures may include (without limitation) transferring your personal data to a recipient that has achieved binding corporate rules authorisation in accordance with applicable data protection laws, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission. In addition, data transfers to recipients in the USA may be protected by an EU-U.S. / Swiss-U.S. Privacy Shield certification.
We retain personal data we collect from you for as long as necessary for the purpose for which your personal data was collected and processed (e.g. to answer a question you asked via e-mail or to comply with applicable legal, tax or accounting requirements).
If we have no longer any legitimate business interest to process your personal data, we will either delete your personal data or anonymise it. Statutory retention periods remain unaffected.
You have the following data protection rights:
This Policy applies only to this Website, and not to websites owned by third parties. We may provide links to other websites which we believe may be of interest to you. We aim to ensure that such websites are of the highest standard. However, due to the nature of the Internet, we cannot guarantee the privacy standards of websites to which we link or be responsible for the contents of sites other than this one, and this Policy is not intended to be applicable to any linked, non-Zeria Group/Tillotts website.