This privacy notice explains how Zenfco Limited collects and processes personal information when you use this website, contact us or otherwise interact with us.
We take the protection of personal information seriously and process it in accordance with applicable data protection laws, including the UK GDPR and Data Protection Act 2018 where they apply.
1. Who we are
Zenfco Limited is the data controller responsible for personal information processed through this website.
Zenfco Limited is incorporated in Hong Kong with company registration number 1925442.
We are registered with the UK Information Commissioner's Office (ICO), registration number ZA367506.
Registered office:
Zenfco Limited
Unit C, 17/F United Centre
95 Queensway
Admiralty
Hong Kong
UK correspondence address:
Zenfco Limited
483 Green Lanes
London
N13 4BS
United Kingdom
Privacy enquiries can be sent to legal@zenfco.com.
2. Personal information we collect
Personal information means information relating to an identified or identifiable individual. We may collect and process the following types of personal information:
- Identity data — such as your name.
- Contact data — such as your email address, telephone number or other contact details that you provide.
- Business data — such as your organisation, role or other professional information where provided.
- Enquiry and correspondence data — information contained in enquiries, messages and other communications with us.
- Technical data — such as IP address, browser type, operating system, device information, referring pages and timestamps.
- Usage data — information about how visitors interact with our website.
- Consent and preference data — records of your cookie and privacy choices.
We may also create aggregated or anonymised information for statistical, analytical and business purposes. Information that can no longer identify an individual is not personal information.
We do not intentionally request special category personal data or information about criminal convictions through this website. Please avoid including such information in free-text enquiries unless it is genuinely necessary.
3. How we collect personal information
We may collect personal information through:
- Direct interactions — when you submit a contact form, email us, speak with us or otherwise communicate with Zenfco.
- Automated technologies — through server logs, cookies, browser storage and similar technologies when you use the website.
- Business partners — where a partner introduces you to us or works with us in connection with a relevant opportunity or joint venture.
Optional analytics and advertising technologies are only enabled where the relevant consent has been provided. Further information is available in our Cookies Policy.
4. How we use personal information
We may use personal information to:
- respond to enquiries and requests;
- discuss our services, capabilities or potential projects;
- assess potential commercial relationships and opportunities;
- manage business development and onboarding activities;
- operate, secure and maintain our website and systems;
- detect and prevent spam, fraud and misuse;
- analyse website performance and improve our content and services;
- measure advertising performance where you have provided the relevant consent;
- maintain business and regulatory records; and
- comply with applicable legal and regulatory obligations.
5. Lawful bases for processing
We will only process personal information where we have a lawful basis to do so. Depending on the circumstances, we may rely on:
- Legitimate interests — where processing is necessary for our legitimate business interests, such as responding to enquiries, managing business relationships, protecting our systems and developing our business, provided those interests are not overridden by your rights and interests.
- Contract or steps before entering into a contract — where processing is necessary to take steps at your request in connection with a potential engagement or to perform an agreement with you.
- Consent — where you have made a specific choice, such as enabling optional analytics or advertising technologies or receiving communications where consent is required.
- Legal obligation — where processing is necessary for us to comply with applicable law or regulation.
Where we rely on consent, you may withdraw that consent at any time. This will not affect processing carried out lawfully before consent was withdrawn.
6. Sharing personal information
We do not sell personal information.
We may share personal information where reasonably necessary with:
- service providers that support our website, hosting, security, email and communications infrastructure;
- analytics and advertising measurement providers where the relevant consent has been given;
- professional advisers such as accountants, auditors, lawyers and other advisers where necessary;
- authorities, regulators or other parties where disclosure is required by law; and
- selected business partners who work with us in connection with business development, joint ventures, opportunity assessment or onboarding.
Where relevant to your enquiry or a potential business opportunity, a selected business partner may receive relevant contact and enquiry information and may contact you directly in connection with that enquiry or opportunity.
Depending on the nature of the arrangement, third parties may process personal information on our instructions or for purposes for which they are independently responsible. Where required, they will provide their own privacy information regarding such processing.
7. Marketing communications
We may contact you in connection with an enquiry, requested information, potential project or existing business relationship.
Where communications constitute direct marketing, we will only send them where permitted by applicable data protection and electronic communications laws. You may object to or opt out of direct marketing at any time.
8. International transfers
Zenfco operates internationally and some of the organisations that provide services to us may process personal information outside the United Kingdom.
Where applicable data protection law restricts an international transfer, we take appropriate steps to protect the information. Depending on the circumstances, these may include transfers to countries covered by applicable adequacy regulations, approved contractual safeguards or other transfer mechanisms permitted by law.
9. Data security
We use appropriate technical and organisational measures designed to protect personal information against accidental loss, unauthorised access, alteration, disclosure or misuse.
Access to personal information is limited to employees, contractors, service providers and other organisations that have a legitimate business need to access it.
We maintain procedures for responding to suspected personal data breaches and will notify affected individuals and relevant regulators where required by law.
10. Data retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including responding to enquiries, maintaining appropriate business records and satisfying legal, accounting or regulatory requirements.
When determining an appropriate retention period, we consider the nature and sensitivity of the information, the purposes for which it is processed, the risks associated with continued retention and applicable legal requirements.
11. Your rights
Depending on the data protection laws applicable to you, you may have rights in relation to your personal information, including the right to:
- request access to personal information we hold about you;
- request correction of inaccurate or incomplete information;
- request deletion of your personal information in certain circumstances;
- request restriction of processing in certain circumstances;
- object to processing based on legitimate interests;
- object to the use of your personal information for direct marketing;
- request transfer of certain information in a portable format; and
- withdraw consent where processing is based on consent.
These rights are not absolute and may be subject to conditions or exemptions under applicable law.
To exercise a privacy right, contact legal@zenfco.com.
12. Cookies and similar technologies
We use cookies and similar technologies as described in our Cookies Policy. That policy contains the current inventory of configured technologies and explains how you can manage your preferences.
13. Complaints
If you have concerns about how we handle your personal information, please contact us first at legal@zenfco.com so that we have an opportunity to investigate.
If you are dissatisfied with our response and UK data protection law applies, you have the right to complain to the Information Commissioner's Office.
You may also have the right to complain to another data protection authority applicable in your jurisdiction.
14. Changes to this privacy policy
We may update this privacy policy from time to time to reflect changes to our website, services, business activities or legal obligations. The date shown at the top of this page indicates when the policy was last updated.