Privacy Policy

BACKGROUND 

ZeroRisk Cybersecurity Limited (“We”, “Our” or “Us”, as applicable) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our website(s) ("Our Website"). We will only collect and use personal data in ways that are described here, and in away that is consistent with our obligations and your rights under the law. By using Our Website, you are consenting to the practices described in this Privacy Policy. 

Please read this Privacy Policy carefully and ensure that you understand it.

1. Definitions and Interpretation  

In this Policy the following terms shall have the following meanings:   

“Account” 

means an account required to access and/or use certain areas and features of Our Website; 

“Cookie” 

means a small text file placed on your computer or device by Our Website when  you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are  set out in Part 14, below;   

“Cookie Law” 

means the relevant parts of the Privacy and Electronic Communications  (EC Directive) Regulations 2003; 

“GDPR” 

means Regulation (EU) 2016/679 on the protection of natural  persons with regard to the processing of personal data and on the free movement of such data.

2. Information About Us 

Our Website are owned and operated by ZeroRisk Cybersecurity Limited, a private limited company registered in the Republic of Ireland under company number 743458 with its registered office at Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland, DO2HW77. 

3. What Does This Policy Cover? 

This Privacy Policy applies only to your use of Our Website. Our Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them. 

4. What Is Personal Data? 

Personal data is defined by the GDPR and the DataProtection Act, 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identified or identifiable natural person... who can be identified, directly or indirectly, in particular by reference to an identifier’. 

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. 

5. What Are My Rights? 

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. 

b. The right to access the personal data we hold about you. Part 13 will tell you how to do this. 

c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more. 

d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more. 

e. The right to restrict (i.e. prevent) the processing of your personal data. 

f. The right to object to us using your personal data for a particular purpose or purposes. 

g. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. 

h. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. 

i. Rights relating to automated decision-making and profiling. We do not use your personal data in this way. 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. 

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with our principal supervisory authority, the Irish Data Protection Commission. Details of how to lodge a complaint can be found on the Data Protection Commissioner’s website. Alternatively, you can contact another local supervisory authority. 

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How? 

Depending upon your use of Our Website, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see our Cookies Policy for information about our use of Cookies and similar technologies.

Data Collected
How We Collect the Data
Identity Information including name and title.
  • When you enter your details on Our Website.
  • When you contact the company.
Contact information including address, e-mail address and telephone number.
  • When you enter your details on our websites.
  • When you contact the company.
Business information including business name, job title and profession.
  • When you enter your details on our websites.
  • When you contact the company.
Payment information including card details and bank account numbers.
  • Collected via Stripe and Charge bee 
  • Payments through suppliers
Technical information including IP address, browser type and version, operating system and platform.
  • IP Address 
  • Technical team may require access to operating system to perform service
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
  • Please refer to our Cookie Policy

7. How Do You Use My Personal Data?  

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. This information is only collected for the purposes of providing our services to you.   

The following table describes how we will use your personal data, and our lawful bases for doing so:

What We Do
What Data We Use
Our Lawful Basis
Registering for our services
  • Name 
  • Job title
  • Business details
  • E-mail
  • Phone number
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
Providing and managing your Account / Service
  • Name
  • Jobe Title
  • E-mail address
  • Phone number
  • Business details
  • Corporate and financial information
  • Payment information
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
  • Contractual necessity
Providing and managing your access to Our Website.
  • Name
  • Job title
  • E-mail
  • Phone number
  • Business details
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
  • Contractual necessity
Supplying our services to you.
  • Name
  • Job title
  • E-mail
  • Phone number
  • Business details
  • Corporate and financial information
  • Payment information
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
  • Contractual necessity
Personalising and tailoring our services for you.
  • Name
  • Job title
  • E-mail
  • Phone number
  • Business details
  • Corporate and financial information
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
  • Contractual necessity
Communicating with you.
  • Name
  • Job title
  • E-mail
  • Business details
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes
Supplying you with information by email that you have opted-in-to (you may opt-out at any time by
  • Name
  • Job title
  • Phone number
  • Business details
  • E-mail
  • Consent
  • Legitimate interests for providing our services to you and/or direct marketing purposes


With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam.   

For non-customers we rely on your consent to contact you and consent will always be provided in the form of a clear opt-in.  You have the right to withdraw your consent at any time using our contact details as listed below. For existing or past customers, we may rely on legitimate interest, being to develop and grow our business, to contact you for marketing purposes.   

We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. 

We will only use your personal data for the purpose(s) for which it was originally collected in a manner compatible with GDPR unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. 

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights. 

8. How Long Will You Keep My Personal Data? 

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.  

For further information about our retention periods, please contact us on the details above.

9. How and Where Do You Store or Transfer My Personal Data? 

We will take reasonable steps necessary for ensuring that your personal data is treated securely and in accordance with this privacy notice.  We will use all reasonable efforts to put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country. 

We might transfer your personal data outside theEuropean Economic Area by enabling remote access to your personal data by our subsidiaries/branches and/or service providers for support services, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers.  

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following: 

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; 
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or theInformation Commissioner’s Office where we are legally required to do so; and 
  • Reasonable procedures and security features to try and prevent unauthorised access.

10. Do You Share My Personal Data? 

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions. 

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy. 

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority, Tax representative, Central Bank, Data Protection Commissioner, Law Enforcement Agencies and other government agencies. 

We may sometimes contract with the following categories of companies to supply certain services or allow access to our systems:

  • Payment service providers
  • Website hosts, advertising partners and marketing agencies
  • Credit reference agencies, law enforcement and fraud prevention agencies.
  • Cloud Server Providers
  • Technical tools and platforms, plugins and applications
  • Third party suppliers
  • IT System Support and Maintenance
  • Offsite Data Backup Providers 

If any of your personal data is shared with a third party, we will provide reasonable notice where necessary and will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.  

Any such third parties are obliged to keep your details securely, and to use them only to fulfil the service that they provide to us, they will dispose of the details in line with their/our data protection policy. If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards. 

If you would like to know more about the third parties’ we may share your personal data with, or to find out more on how they will use your data, please contact us using the details at Part 15.   

11. How Can I Control My Personal Data? 

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emailsat the point of providing your details and by managing your Account). 

12. Can I Withhold Information? 

You may access certain areas of Our Website without providing any personal data at all. However, to use all features and functions available on Our Website you may be required to submit or allow for the collection of certain data. 

You may restrict our use of Cookies. For more information, see our Cookies Policy. 

13. How Can I Access My Personal Data? 

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “Subject Access Request”. 

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.  

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. 

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.

If you make a request to erase/be forgotten data, we will do so where we do not hold a legal obligation to keep this data. 

If you would like to update any personal details, please contact us on the details provided at Part 15. 

14. How Do You Use Cookies? 

For information about how we use cookies, please see our Cookie Policy. 

15. How Do I Contact You? 

To contact our Privacy Team about anything to do with your personal data and data protection, including to make a subject access request, please use the following contact details:

Address:

Block 4 Harcourt Centre
Harcourt Road
Dublin 2
Ireland
D02 HW77 

Email address:

privacy@zerorisk.io

16. Changes to this Privacy Policy 

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. 

Any changes will be immediately posted on websites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Website following the alterations. We recommend that you check this page regularly to keep up-to-date.  

This Privacy Policy was last updated on 26 July 2023.