Privacy & Cookie Policy
1. Introduction
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1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to Network Z, a trading style of Zephyros Enterprise Network Ltd. For more information about Network Z and our company details, see Section 19.
1.5 Scope. This notice covers: (a) visitors/consumers using zpages.net; and (b) members and potential members who apply for or hold a Zpages listing.
1.6 Controller (visitors/members). For activity on zpages.net and for membership applications and account administration, Network Z (Zephyros Enterprise Network Ltd) is the data controller.
1.7 Controller (contacting a zpage owner). If you contact or transact with a business via its individual zpage, that zpage owner is the data controller for that interaction. We provide the publishing platform and may process data on their instructions to host and route forms. Any data that is submitted via this website is covered by these terms, but any data given to a zpage owner by telephone, in person, by text message or by email is the sole responsibility of the zpage member and cannot be monitored or controlled by Network Z. Please read the zpage owner’s own Privacy Policy before submitting personal data to them.
2. How we use your personal data
2.1 In this Section we set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 Usage/analytics data. We may process technical data about how you use our site (“usage data”), such as IP address, device/browser, pages viewed and session timings, to operate and secure the service (legitimate interests). We will only run analytics or other non-essential cookies/scripts with your consent via the cookie banner (consent).
2.3 Account data. We may process account data (e.g., name, email) that you provide. The data is used to operate the website, provide services, ensure security, maintain backups and communicate with you (contract / legitimate interests / consent, as applicable).
2.4 Profile/listing data. If you create or provide a profile/listing, we process the fields you submit (typically name, business details, contact information and media) to enable your listing and manage your account (contract / legitimate interests).
2.5 Publication data. Information you post for publication on our website or through our services may be processed to enable such publication and to administer our website and services (consent / legitimate interests / contract).
2.6 Enquiry data. Information contained in any enquiry you submit about goods and/or services may be processed to respond and, where relevant, to offer and provide those goods/services (consent / contract).
2.7 Customer relationship data. We may process information relating to our customer relationships, including contact details and communications, for relationship management and record-keeping (legitimate interests / consent).
2.8 Transaction data. We may process information relating to purchases of goods or services (contact details and transaction details) to supply purchases and keep proper records (contract / legal obligation / legitimate interests). We do not store full card details; payments are processed by our payment provider.
2.9 Notification/marketing data. If you subscribe to notifications or newsletters, we process your details to send them (consent or soft opt-in where permitted; you can opt out at any time).
2.10 Correspondence data. We may process information contained in or relating to communications you send to us (content and metadata) for communications and record-keeping (legitimate interests).
2.11 Legal claims. We may process personal data where necessary for the establishment, exercise or defence of legal claims (legitimate interests).
2.12 Risk/insurance. We may process personal data for obtaining or maintaining insurance coverage, managing risks or obtaining professional advice (legitimate interests).
2.13 Compliance/vital interests. We may process personal data where necessary for compliance with a legal obligation, or to protect your vital interests or the vital interests of another natural person.
2.14 Special category data. Please do not include health, biometric or other special category data in free-text fields. If such processing is necessary, we will agree appropriate safeguards with you first.
2.15 Please do not supply any other person’s personal data to us unless we prompt you to do so or you have their permission.
3. Automated decision-making
3.1 We do not use your personal data for automated decision-making that produces legal or similarly significant effects.
4. Providing your personal data to others
4.1 We may disclose your personal data to our group companies insofar as reasonably necessary for the purposes and legal bases set out in this policy.
4.2 We may disclose personal data to our insurers and/or professional advisers for insurance, risk management, professional advice or legal claims.
4.3 Service providers (processors). We use trusted vendors (e.g., website hosting, email, analytics, payment processors) who act as our processors under written agreements. They may process personal data only on our instructions and must keep it secure.
4.4 Transactions. Transactions relating to our website and services may be handled by third-party service providers. We will share transaction data with them only to the extent necessary to process payments and address related queries.
4.5 Referrals to zpage owners. If you choose to contact a business listed on zpages.net, we may pass your enquiry to that zpage owner so they can respond. In doing so, the zpage owner becomes the controller for that enquiry and their privacy notice applies.
4.6 We may disclose personal data where necessary for compliance with a legal obligation, to protect vital interests, or for the establishment, exercise or defence of legal claims.
5. International transfers of your personal data
5.1 Some of our service providers may process data outside the UK/EEA.
5.2 Safeguards. Where data is transferred internationally, we rely on:
(a) a UK adequacy regulation for the destination country; or
(b) appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or EU Standard
Contractual Clauses with UK addendum, plus supplementary measures where needed.
5.3 You acknowledge that personal data submitted for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section sets out our data retention policies and procedures, designed to help ensure compliance with our legal obligations.
6.2 Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.
6.3 Retention schedule (summary):
• Enquiries (site-wide): up to 12 months.
• Member/account/billing records: up to 6 years after the end of the financial year (legal/tax).
• Marketing contacts: until you opt out or object.
• Website logs/security data: up to 12 months.
We may retain data longer where required by law or to establish/exercise/defend legal claims.
6.4 Notwithstanding the other provisions of this Section, we may retain personal data where such retention is necessary for compliance with a legal obligation or to protect vital interests.
6.5 Backups. Content removed from the live site may persist in encrypted backups for up to 90 days before being overwritten.
7. Security of personal data
7.1 We take appropriate technical and organisational precautions to secure personal data and to prevent loss, misuse or alteration.
7.2 We store personal data on secure systems (servers, devices and secure record-keeping). Access is limited to personnel who need it.
7.3 Transmission of data over the internet is inherently insecure; we cannot guarantee the security of data sent online.
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 Please check this page occasionally to ensure you are happy with any changes.
8.3 We may notify you of significant changes by email or via notices on our website.
9. Your rights
9.1 Your principal UK data protection rights include:
(a) access; (b) rectification; (c) erasure; (d) restriction; (e) objection; (f) data portability; (g) complaint to a supervisory authority; and (h) withdrawal of consent.
9.2 You have the right to confirmation as to whether we process your personal data and, where we do, access to that data and certain additional information. Subject to the rights and freedoms of others, we will provide a copy of your personal data. The first copy is free; additional copies may incur a reasonable fee.
9.3 You have the right to have inaccurate personal data rectified and incomplete data completed.
9.4 In some circumstances you have the right to erasure of your personal data without undue delay, subject to legal exemptions.
9.5 In some circumstances you have the right to restrict processing.
9.6 You have the right to object, on grounds relating to your particular situation, to processing based on legitimate interests, and to direct marketing (including profiling for such purposes).
9.7 Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
9.8 You may exercise your rights by emailing us (see Section 19.3).
10. Third-party websites
10.1 Our website may include links to third-party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons 18+ only.
11.2 If we learn that we hold personal data of a person under that age, we will delete it.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. When we act as a processor
13.1 In some cases (e.g., hosting a form for a zpage owner), we may process personal data on the owner’s instructions as their processor. In those cases, this policy primarily does not apply; our obligations are set out in our contract with the relevant controller.
14. About cookies
14.1 A cookie is a small file placed on your device. It may be a session cookie (expires when you close your browser) or a persistent cookie (remains until it expires or you delete it).
14.2 Cookies do not typically identify you directly, but certain cookies may be linked with information that could identify you.
15. Cookies that we use
15.1 We use cookies for:
(a) strictly necessary purposes (e.g., security, load balancing, consent logging);
(b) preferences/personalisation (if used);
(c) analytics — only with your consent;
(d) advertising/marketing — only with your consent;
(e) cookie consent — to remember your choices.
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15.2 Our analytics may collect IP address, approximate location, device and browser type, and session metrics (page response times, length of visits, page interactions). Analytics runs only after consent.
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16. Cookies used by our service providers
16.1 Our service providers may use cookies when you visit our site.
16.2 For example, we may use Google Analytics to analyse website use. Google’s privacy policy: https://www.google.com/policies/privacy/
Analytics only runs after consent via the cookie banner (and, where applicable, via consent mode).
16.3 If you make payments through our website, our payment processor will collect necessary payment information. We do not store full card details.
17. Managing cookies
17.1 Most browsers allow you to refuse or delete cookies. Up-to-date information is available at:
(a) Chrome: https://support.google.com/chrome/answer/95647?hl=en
(b) Firefox: https://support.mozilla.org/kb/enable-and-disable-cookies-website-preferences
(c) Opera: http://www.opera.com/help/tutorials/security/cookies/
(d) Internet Explorer: https://support.microsoft.com/help/17442
(e) Safari: https://support.apple.com/kb/PH21411
(f) Edge: https://privacy.microsoft.com/windows-10-microsoft-edge-and-privacy
17.2 Blocking all cookies may negatively affect your experience of many websites.
18. Cookie preferences
18.1 You can manage non-essential cookies at any time using our cookie banner/preferences centre (link in the footer). You can also adjust your browser settings. Essential cookies are required for the site to function.
19. Our details
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19.1 Network Z and Zpages are trading styles of Zephyros Enterprise Network Ltd.
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19.2 Zephyros Enterprise Network Ltd is registered in England & Wales under company number 10513903. Registered office: Thornton House, Cemetery Road, Stoke-on-Trent, ST4 2DL, UK.
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19.3 You can contact us:
(a) using our website contact form; or
(b) by email to admin@zpages.net
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