questionZERO Privacy Policy

questionZERO respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website, www.questionzero.com (our site) (regardless of where you visit it from), when you access and use our services or otherwise contact us. It will also tell you about your privacy rights and how the law protects you.

References to you or your include you as an individual using our site and services.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

1.1. This privacy policy gives you information about how we collect and use your personal data through your use of our site (including how we collect and process data you provide us through this site) when you register with us, use our service, sign up to our newsletter or take part in a competition

Data Controller

1.2. EcoHub Technologies Limited is the controller with responsibility for your personal data (referred to as questionZERO, we, us or our in this privacy policy).

1.3. If you have any questions about this privacy policy, including any requests to exercise your legal rights (as set out in paragraph 9), please contact us using the information set out in paragraph 10.

2. IMPORTANT INFORMATION AND WHO WE ARE

2.1. Personal data means any information about an individual from which that person can be identified.

2.2. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email addresses and telephone numbers.
• Financial Data includes payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• 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, device ID and other technology on the devices you use to access our site.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our site and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.3. We also collect, use and share aggregated data such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of customers accessing a specific site feature in order to analyse general trends in how customers are interacting with our site to help improve our site and our service offering. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

3.1. We use different methods to collect data from and about you, including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account on our site
  • subscribe to our publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our site, we will automatically collect Technical Data about your equipment, browsing actions and patterns, including the links you have clicked on from our site. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Information we receive from other sources. As you interact with advertising and social networks, we may receive personal data about you from various third parties, such as Google and Facebook, where you choose to access and register to our site via registration plug-ins.

4. HOW WE USE YOUR PERSONAL DATA

Legal basis

4.1. The law requires us to have a legal basis for collecting and using your personal data. There are six such permitted legal bases for processing personal data. We primarily rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example, to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example, if you subscribe to an email newsletter.

Purposes for which we will use your personal data

4.2. We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

4.3. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view of what we think you may want or need or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

4.4. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing. Otherwise, we will only send unsolicited electronic direct marketing communications with your consent.

Third-party marketing

4.5. We will get your express opt-in consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

4.6. You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at any time using the contact details in paragraph 10.

4.7. Where you opt out of receiving marketing communications, this will not apply to personal data provided to us in the course of performing our services for you.

Cookies

4.8. You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy.

5. DISCLOSURES OF YOUR PERSONAL DATA

5.1. Sometimes, we need to disclose your personal data to other people.

5.2. We may share your personal data where necessary with the categories of external third parties set out below, who provide support integral to the provision of our services and enable us to operate, such as:

• Professional advisers, including lawyers, bankers, auditors, insurers and employment and recruitment agencies based in the UK (or other relevant jurisdictions) who provide consultancy, banking, legal, insurance, accounting and recruitment services.
• Suppliers and service providers such as providers of affiliate networks, digital services, data hosting, IT support and payment services providers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses, and we will, as far as possible, share anonymised data with the other parties before the transaction is completed. Once the transaction is completed, we will share the personal data with the other parties if and to the extent required under the terms of the transaction, and in any case, in the same way as set out in this privacy policy.
• Marketing and advertising agencies who help us with social media and other marketing.
• Retailers who will use such information to provide relevant marketing and promotions.

5.3. We prepare anonymous datasets about our customers' use of our site, which may be shared externally with third parties such as investment firms and research organisations. The information used and shared in this way is not personal data, and customers cannot be identified from it.

5.4. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

6.1. We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

6.2. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK, which give personal data the same protection it has in the UK.

7. DATA SECURITY

7.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How long will you use my personal data for?

8.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

8.2. To determine the appropriate retention period for personal data, we consider 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, regulatory, tax, accounting or other requirements.

8.3. In some circumstances, you can ask us to delete your data; see paragraph 9 below for further information.

8.4. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

9.1. You have a number of rights under data protection laws in relation to your personal data.

9.2. You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling, legitimate grounds to process your information, which override your right to object.
• You also have the absolute right to object at any time to processing your personal data for direct marketing purposes (see "Opting out of Marketing" in paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy,
  • Where our use of the data is unlawful, but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

9.3. If you wish to exercise any of the rights set out above, please use the contact details in paragraph 10.

No fee is usually required

9.4. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

9.5. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other 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 may also contact you to ask you for further information in relation to your request to speed up our response

Time limit to respond

9.6. We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CONTACT DETAILS

10.1. If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your privacy rights, please use our contact form here.

11. COMPLAINTS

11.1. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

12. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

12.1. We keep our privacy policy under regular review. This version was last updated in December 2024.

12.2. 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, for example, a new email address.

13. THIRD-PARTY LINKS

13.1. Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.