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.
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.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
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.
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:
Our full details are:
Full name of legal entity:
Zinc Educational Services Inc.
Name or title of data privacy manager:
41 Union Square West, Suite 602
New York, NY 10003
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.
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.
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.
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.
We collect your data in different ways, such as:
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
Performance of a contract with you
To process your payment
(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:
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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)
‘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.
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.
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:
This cookie is essential for our site to:
This cookie enables us to:
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.
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.
If you wish to exercise any of the rights set out above, or if you have any questions about them, please contact us.
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.
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.
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.