Privacy policy
1 About Us
1.1 We are Zaoui & Co SA and Zaoui & Co Ltd (together “Zaoui” or “we”), and we can be contacted regarding this privacy policy (the “Policy”) at dataprotection@zaouico.com. Any Personal Data processed by Zaoui is controlled by us, and so we are considered the data controller of your Personal Data.
1.2 We are subject to the General Data Protection Regulation (EU) 2016/679 (the “EU GDPR”) and the EU GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) (together the “GDPR”) when we obtain, use, disclose, store or otherwise process your Personal Data.
2 About this Policy
We are committed to protecting your Personal Data and respecting your privacy.
This policy explains about the Personal Data that we may collect from you, use and otherwise process in connection with your relationship with Zaoui, including in connection with your use of our website. In particular, we explain the kinds of Personal Data that we may collect from you, how we collect it, what we use it for and with whom we may share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or a relevant regulator in the event you have a complaint. By “Personal Data” we mean information about you where you are, or could be, identified.
For easy access to the sections of this Policy, please click on the hyperlinks below:
- About Us
- About this Policy
- Personal Data We Collect
- How We Collect Your Personal Data
- Why We Collect Your Personal Data
- Who Else May Have Access to Your Personal Data
- Countries Having Access to Your Personal Data
- Retention of Your Personal Data
- Your Rights
- Cookies and Other Similar Technologies
- Children’s Privacy
- Links to Other Websites and Services
- Contacting Us
- Policy changes
- Making a Complaint
3 Personal Data We Collect
3.1 The Personal Data we collect about you depends on your relationship with us. The Personal Data we collect from you could be about how you access our website or the particular services we provide to you. We will collect and use the following Personal Data about you:
– your name and contact information, including email address and telephone number; and
– your IP address and other unique identifiers.
3.2 Our vendors, clients and business partners may also provide us with certain information about their staff in line with the Personal Data listed above. We process this Personal Data so we can liaise with such parties about the services we provide, the services provided to us, to support, grow and maintain the relationship we have with such parties.
3.3 We do not knowingly collect any special category data about our clients, vendors or business partners.
4 How We Collect Your PERSONAL DATA
4.1 We collect Personal Data from you directly when you enter or send us information, such as when we provide our services to you, indirectly such as your browsing activity while you use our website or indirectly through companies or agents we work with.
4.2 Where we provide services to you, these may include:
– the provision of corporate financial advisory services to our clients and prospective clients;
– the website owned and controlled by us that link to this Policy; and
– our marketing and business development activities, including meetings you may attend and emails that we send.
4.3 If you are applying for a role with us, we may collect Personal Data about you. For more information, please refer to our Candidate Privacy Policy on our recruitment portal at https://zaoui-co.sainoo.com/careers.
5 Why We Collect Your PERSONAL DATA
5.1 Under data protection law, we can only use your Personal Data if we have a proper reason, for example: where you have given consent; to comply with our legal and regulatory obligations; for the performance of a contract with you or to take steps at your request before entering into such contract; or for our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests.
5.2 The table below explains how we may use your Personal Data and why.
| What we use your Personal Data for | Our reasons |
| Conduct our business and provide our services. | To perform our contract with you or to take steps at your request before entering into a contract. |
| Communicate with you not related to marketing. | To perform our contract with you or to take steps at your request before entering into a contract. |
| Comply with our security and legal obligations. | To comply with our legal and regulatory obligations. |
| Prevent, investigate, or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or use of your Personal Data, our networks, systems or applications. | To comply with our legal and regulatory obligations, and for our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us. |
| Enforce legal rights or defend or undertake legal proceedings. | Depending on the circumstances: — to comply with our legal and regulatory obligations; and/or — in other cases, for our legitimate interests, i.e. to protect our business, interests and rights. |
6 Who Else May Have Access to Your PERSONAL DATA
6.1 We may share your Personal Data with service providers that provide support services to us. Service providers are third parties who perform services on our behalf. They are contractually restricted from using your Personal Data in any manner other than in helping us to provide you with our services.
6.2 We routinely share Personal Data with:
– third parties we use to help deliver our services to you, e.g. data hosting providers; and
– other third parties we use to help us run our business, e.g. website hosts and website analytics providers.
6.3 We or the third parties mentioned above occasionally also share Personal Data with:
– our and their external auditors, e.g. in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations; our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
– law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
– other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible.
6.4 We may also disclose your Personal Data to a third party when you ask us to do so.
6.5 If you would like more information about who we share our data with and why, please contact us.
7 Countries Having Access to Your PERSONAL DATA
7.1 Our servers, storing and keeping your personal data secure, are located in the European Economic Area.
8 Retention of Your PERSONAL DATA
8.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, to provide our services or to process your application, or to keep you up to date with Zaoui as a firm.
8.2 Different retention periods apply for different types of Personal Data. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized 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.
8.3 Following the end of the relevant retention period, we will delete or anonymise your Personal Data. In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such anonymized information without further notice to you.
9 Your Rights
9.1 You generally have the following rights, which you can usually exercise free of charge:
9.1.1 access a copy of your Personal Data that we are processing;
9.1.2 have your Personal Data corrected if it is inaccurate, outdated or incomplete at any time (known as rectification);
9.1.3 erasure, or the right to be forgotten, which means you can request deletion or removal of your Personal Data in certain situations;
9.1.4 require us to restrict processing of your Personal Data in certain circumstances, e.g. if you contest the accuracy of the data;
9.1.5 receive the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations;
9.1.6 object at any time to your Personal Data being processed for direct marketing (including profiling), or in certain other situations, the right to object to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests;
9.1.7 not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not currently use any automated decision making using your Personal Data;
9.1.8 where you have given us your consent, withdraw your consent at any time by contacting us as described in this notice, or where applicable, by unsubscribing from any communications to which you have subscribed;
9.1.9 bring complaints with any relevant data protection or privacy authority (see section below for further details).
9.2 To make any requests as listed above, please contact us at dataprotection@zaouico.com.
9.3 We will confirm any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.
9.4 Given we operate in a regulated industry, we are required to obtain certain information before we can accept someone as a client. If you do not provide the Personal Data we ask for, it may delay or prevent us from providing the services to you. If you request that your Personal Data is deleted from our records, there may be a reasonable delay in processing that request, while we or our designee verifies that the request is valid and originates from you. Please note, a copy of some or all of the Personal Data may be retained for legal compliance purposes. If you request that your Personal Data be deleted, we reserve the right to terminate and/or limit your access to our websites.
10 Cookies and Other Similar Technologies
10.1 Our website uses “cookie” technology. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies to distinguish you from other visitors, track your IP address and usage of our site. We do not otherwise track any information about your use of other websites. Non-Personal Data or anonymised/pseudonymised information obtained through cookies may be shared with or obtained by service providers on our behalf.
10.2 A “session cookie” expires immediately when you end your session (i.e., close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to the same website at a later date, the cookie information is still available.
10.3 When you visit our website, we may use both session and persistent cookies. This Zaoui-placed cookie may contain information that is used to track your usage of our website.
10.4 We may use Flash Cookie (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed in a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalise and enhance your online experience, facilitate processes, personalise and store your settings. Flash cookies are different from browser cookies, and the cookie management tools provided by your browser will not remove Flash cookies.
10.5 We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.
10.6 You can disable cookies at any time by using your browser options (usually found in the “Privacy” and/or “Security” settings). It may be necessary to refresh the page for the updated settings to take effect. This may cause the cookie preferences banner to reappear, letting you update your preferences. Please note, if you do not want to accept cookies, you may lose some of the functionality of our website.
10.7 You can find out more about cookies by following this link: https://ico.org.uk/for-the-public/online/cookies/.
11 Children’s Privacy
11.1 Given the nature of our website and services, we do not knowingly collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older.
11.2 If you are under 16, do not use or provide any information about yourself to us, including your name, address, telephone number or email address.
11.3 If we learn we have collected or received Personal Data from a child under 16, we will delete that information.
11.4 If you believe we might have any information from or about a child under 16, please contact us at dataprotection@zaouico.com.
12 Links to Other Websites and Services
12.1 Our website may include links to other Internet sites or content (embedded or direct links) maintained by third parties (“Linked Sites”). We provide Linked Sites to you solely for information, and the inclusion of Linked Sites does not imply endorsement by us of the Linked Sites. You access Linked Sites at your own risk, and by accessing them you leave our website. Linked Sites are not under our control, and we are not responsible for the contents of any Linked Site, including the privacy policies or tracking technologies they may use. We encourage you to check the applicable privacy policy to determine how they will handle any Personal Data they collect from you.
13 Contacting Us
13.1 Please contact us if you have any queries or concerns about our use of your Personal Data. You can contact us by email or post if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
13.2 Our contact details are shown below.
| UK | EEA | |
|---|---|---|
| Email address | dataprotection@zaouico.com | dataprotection@zaouico.com |
| Postal address | 23 Hill Street London W1J 5LW UK |
62, avenue Victor Hugo L-1750 Luxembourg |
14 Policy changes
This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.
15 Making a Complaint
15.1 Please contact us in the first instance if you have a concern about our use of your Personal Data, we hope we will be able to resolve any issues you may have.
15.2 However, you also have the right to lodge a complaint with the Information Commissioner if you are based in the UK at https://ico.org.uk/make-a-complaint or via telephone at 0303 123 1113. If you are in Luxembourg or the EU, you have submit a complaint with the Commission Nationale pour la Protection des Données at https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html.