Privacy Policy




Welcome to Zinc Educational Services Inc’s (Zinc) privacy notice.

Zinc respects your privacy and is committed to protecting your personal data. This privacy notice will explain how we look after your personal data when you visit our payment portal and tell you about your privacy rights and how the law protects you.

Some parts of this privacy policy are aimed at users who are based in the EU, as they are afforded certain rights under the GDPR. We have made a distinction where this is the case, so please ensure you read and understand these additional provisions if they apply to you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.







7.         [DATA SECURITY]

8.         [DATA RETENTION]

9.         [YOUR LEGAL RIGHTS]

10.         [GLOSSARY]

  1. Important information and who we are
  1. Purpose of this privacy notice

This privacy notice explains how Zinc collects and processes your personal data through your use of this website, including any data you may provide when you use our payment portal.

  1. Controller

Zinc is the controller, which means we are responsible for your personal data.

If you have any questions about this privacy notice and your legal rights, please contact our data privacy manager using the details below:

  1. Contact details

Our full details are:


Full name of legal entity:

Zinc Educational Services Inc.

Name or title of data privacy manager:

Business Manager

Email address:


Postal address:

41 Union Square West, Suite 602

New York, NY 10003

Telephone number:


You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Our EU representative is Patrick Weber, Attorney, Tacitus Str. 1 e50968 Köln, Germany.

  1. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. The data we collect about you
  1. Personal data, or personal information, means any information which can identify you. It does not include data where the identity has been removed (anonymous data).
  2. We may collect, use, store and transfer different kinds of personal data about you, such as:
  1. Identity Data includes first name, last name, username, date of birth and gender.
  2. Contact Data includes billing address, email address and telephone numbers.
  3. Financial Data includes bank account and payment card details.
  4. Transaction Data includes details about payments from you.
  5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Profile Data includes your grades and school name if you are a student.
  7. Usage Data includes information about how you use our payment portal.  

We do not collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, nor do we collect any information about criminal convictions and offences.

  1. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data, we may not be able to perform the contract we have or are trying to enter into with you.

  1. How is your personal data collected?

We collect your data in different ways, such as:

  1. Direct interactions -You may give us your Identity, Contact and Financial Data by using the payment portal.
  2. Automated technologies or interactions – As you use our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
  1. How we use your personal data
  1. We will only use your personal data when the law allows us to and mainly:
  1. Where we need to perform the contract we are about to enter into or have entered into with you.
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. Where we need to comply with a legal or regulatory obligation.
  1. Purposes for which we will use your personal data

We are legally required to let you know how we will use your data and what our lawful basis is for using your data. We have set out below, in a table format, a description of this.



Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer and set up your account

(a)        Identity

(b)        Contact

Performance of a contract with you

To process your payment

(a)        Identity

(b)        Contact  

(c)        Financial

(d)        Transaction

(e)        Marketing and Communications

(a)        Performance of a contract with you

(b)        Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a)        Letting you know about changes to our terms or privacy policy

(a)        Identity

(b)        Contact

(c)        Profile

(a)        Performance of a contract with you

(b)        Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a)        Technical

(b)        Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

  1. Cookies

‘Cookies’ are small pieces of information stored on the hard drive of your computer which contain information about you. The information is used to track your use of the website and to compile statistical reports on website activity.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

We use the following cookies:

Strictly necessary cookies

These cookies are necessary for our website to operate, for example they let you log into secure areas of our website.

Analytical/performance cookies

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:





More information

Strictly necessary cookies


This cookie is essential for our site to:

  • Maintain security and verify your details whilst you use the website as you navigate from page to page, which enables you to avoid having to re-enter your details each time you enter a new page.

Analytics/Performance cookies



This cookie enables us to:

  • Estimate our audience size and usage pattern.


  1. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where the law allows us or requires us to do so.

  1. Sharing your personal data
  1. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
  1. Other companies in our company’s group.
  2. Service providers
  1. Authorize.Net: a leading payment gateway since 1996, to accept credit cards and electronic check payments safely and securely for our customers. For additional information regarding the privacy of your sensitive cardholder data, please read the Authorize.Net Privacy Policy 
  1. Professional advisers, such as our lawyers, bankers, auditors and insurers.
  2. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  1. We ask all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
  1. International transfers if you are based in the EU
  1. If you are based in the EU, your personal data will be transferred outside the EEA as we are based in the United States.  Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal information.
  2. We rely on your explicit consent, which we obtain at the point at which you sign up to use our
    payment portal, in order to transfer your personal data outside EEA.
  1. Data security
  1. We have put in place appropriate security measures to keep your personal data safe. In the event of a suspected breach of personal data, we will notify you and the ICO where we are legally required to do so.  
  1. Data retention
  1. How long will you use my personal data for?

We will only store your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In deciding how long to keep your data, we think about the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Please contact us if you would like more details about how long we keep your data for.

  1. Your legal rights if you are based in the EU
  1. The GDPR gives you certain rights in relation to your personal data.
  1. You can ask to get a copy of the personal data we hold about you.
  2. You can ask us to correct your personal data.
  3. You can ask us to delete your personal data, for example if there is no good reason for us to continue processing it. There are some cases in which we may not be able to delete your data, but we will let you know if that applies.
  4. You can object to our processing of your data, for example if we are doing this for marketing purposes, or if you think that our processing impacts on your fundamental rights and freedoms.
  5. You can ask us to suspend processing your personal data in certain situations, for example if you have objected to our use of your data but we need to verify if we have overriding legitimate grounds to use it.
  6. You can ask us to transfer your personal data to a third party in specific situations.
  7. You can withdraw your consent at any time where are relying on your consent to process your personal data.

If you wish to exercise any of the rights set out above, or if you have any questions about them, please contact us.

  1. No fee usually required

You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee, or refuse to deal with your request, if your request is clearly unfounded, repetitive or excessive.

  1. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure you are able to exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

  1. Time limit to respond

We try to respond to all legitimate requests within one month. Sometimes, we might need longer than a month, but we will let you know if that is the case.  

  1. Glossary
  1. Lawful Basis
  1. Legitimate Interest means the interest of our business in managing our business so that we can give you the best service and experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where the impact on you overrides our interests.
  2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  3. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.