1. Introduction

To run our business, we processes information about natural and legal persons (“Personal Data”), including information about its prospective, current and former clients as well as visitors and users of this website (“you”).

Personal Data is all information relating to an identified or identifiable person.

Processing includes all actions that can be performed on Personal Data such as collecting, organizing, storing, using, disclosing or otherwise making available, restricting or destroying. As part of our commitment to protect your Personal Data, we want to inform you in a transparent manner how Zeno SA and its affiliates (“Zeno”) processes your Personal Data and your rights regarding your Personal Data.

2. Personal Data collected by Zeno

The nature of the Personal Data we collect depends on your relationship with Zeno and may include the following (to the extent permitted by applicable law):

Website visitor or user

  • Basic Personal Data such as name, job title, and business name.
  • Contact information such as email address, postal address, and telephone number.
  • Online electronic information such as cookies information, IP address, engagement statistics, usage analytics, IT traffic and action traffic (including content accessed, shared, or downloaded), user login details, if you use Zeno’s websites. Please see our Cookies Policy.
  • Information you provide when you fill in forms, or register to receive information from Zeno, subject to your consent or any other requirements under applicable laws.
  • Information related to electronic interactions with Zeno or its service providers (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.

Potential contractual counterparty, or a contractual counterparty that has not received a more specific privacy notice

  • Basic Personal Data such as name, job title, and business name.
  • Contact information such as email address, postal address, and telephone number.
  • Biographical information.
  • Information to confirm your identity and for security and safety reasons when you visit Zeno’s premises (such as checking your ID, and CCTV video images in compliance with applicable laws).
  • Information related to electronic interactions with us or our service providers (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.
  • Other Personal Data disclosed in the context of the contract, or where required under contract, applicable law or regulations.

Zeno primarily obtains your Personal Data directly from you, including data about your usage of the website services and actions. Some Personal Data may be inferred from the information you provide or arise in the context of managing our relationships with you. Additionally, we may receive Personal Data about you from third parties such as third-party data providers, and from publicly available sources.

3. Purposes of processing your Personal Data

We process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process your Personal Data, within applicable legal limitations, for the following purposes:

3.1. Identity Verification and Management

As part of providing services, or information about our services, to you, we may need to verify your identity to accept you as a client. This may include third parties carrying out identity checks on our behalf. We will need to continue processing your data in order comply with our legal and regulatory obligations.

We process your Personal Data for these purposes on the basis of our legal obligations and/or to enter or perform a contract with you.

3.2 Provisions, Improvement and Development of Products and Services

We use your Personal Data to perform our services and comply with our obligations to you.

We may regularly review your needs to ensure that you get the best possible products and services from us. We may from time to time use the Personal Data provided by you through your use of our services and/or through client surveys as well as through the use of our website to help us improve our products and services.

We process Personal Data for these purposes to perform a contract with you, on the basis of our legitimate interest in improving our services and/or based on your consent, when you have given us such consent.

3.3. Compliance, Risk management, Settlement of Enquiries and Disputes

We will need to process your Personal Data to comply with our record keeping obligations and other legal obligation, with directives and recommendations of authorities, court orders, our internal directives, as well as for risk management purposes. We may also need to process your Personal Data when reporting to regulatory bodies or for internal and external audit purposes.

Where we consider there to be a risk that we may need to defend or bring legal claims, we may process your Personal Data as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims.

We process Personal Data for these purposes on the basis of our legal obligations and/or based on our legitimate interest in defending or enforcing claims and in managing risks.

3.4. Profiling

We process some of your data with the goal of automatically assessing certain aspects of your personality (profiling). We may do so in particular to comply with our legal and regulatory obligations (e.g. to combat money laundering and terrorism financing), to protect you and ourselves against fraudulent activities and other security risks; and to tailor our offer and marketing to you, and to improve our products and services (e.g. by conducting statistical analyses and for operational planning).

4. Persons who have access to your Personal Data

Zeno will never sell your Personal Data.

In the course of Zeno’s activities and for the same purposes as those listed in this Privacy Notice, your Personal Data may be accessed by or transferred to the following categories of recipients to achieve such purposes:

  • Zeno’s personnel (e.g., personnel with management, compliance, communications, human resources, IT, client services, internal audit, finance and other functions);
  • suppliers and service providers (e.g. outsourced service providers, and providers of due diligence and similar checks);
  • technology systems providers, including cloud and database providers, and related consultants;
  • any third parties to whom Zeno assigns its rights and obligations;
  • Zeno’s professional advisors and external lawyers; and
  • it’s banks, lenders, and external auditors where lawfully required.

Such recipients are obligated to protect the confidentiality and security of your Personal Data.

In limited circumstances, your Personal Data may be accessed by or transferred to law enforcement, regulatory bodies, or judicial authorities. This will occur only when legally required.

Your Personal Data may be processed by Zeno in a different country than where you are based. For example, a service provider in another country may process your personal data. The data protection legislation in such other country may not give you as much protection as the data protection legislation in the country where you are located.

We ensure that any transfer is made in accordance with applicable data privacy law. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as the European Commission Standard Contractual Clauses.

6. Personal Data protection

Zeno implements technical and organizational measures to provide an appropriate level of security and confidentiality to your Personal Data. These measures consider the state of the art of the technology; the costs of its implementation; the nature of the data; and the risk of processing.

The purpose of these measures is to protect your personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and against other unlawful forms of processing. Please note that these protections do not apply to Personal Data you choose to share in public areas such as on community websites. Please also note that there are inherent risk to the transmission of Personal Data over the Internet and the electronic storage of data. We cannot guarantee absolute security of your information.

7. Retention period of your Personal Data

In principle, we will retain your data the entire duration of your contractual relationship with us, and for a period of 10 years after the termination of our business relationship with you or after the end of the transaction, as required by law. We may retain your data for longer in specific circumstance, for instance if legally or contractually required to do so or if your data is required to defend or bring a legal claim. In that case, the retention period of your information will be limited to what is legally required or necessary for the relevant purpose.

8. Your rights

8.1. Access, correction and erasure of your Personal Data

Upon your request, we will send you a copy of your Personal Data that we hold. This will be provided to you without undue delay in a structured, commonly used and machine-readable form.

We want to make sure that your Personal Data is accurate and up to date. You may ask us to correct, complete or remove information you think is inaccurate. If we hold your Personal Data and you want it to be removed from our database or inactivated, please contact us at contact@zenopartnes.com.

8.2. Right to oppose the use of your Personal Data and to opt out of marketing communication

You have the right to ask us not to process your Personal Data. You can exercise your right to object by contacting us at contact@zenopartners.com. If you wish to opt out of marketing, our emails will also have an “unsubscribe” option available in the footer of our Website.

8.3. Right to withdraw consent

In the event that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time.

8.4. Complaint

You always have a right to file a complaint with a supervisory authority or directly to us by sending an e-mail to contact@zenopartners.com.

8.5. Possible consequences of and limits to the exercise of your rights

The exercise of certain of your rights (e.g. your objection to the processing of your Personal Data or withdrawal of any previously given consent) may prevent us from granting you access to this website and/or offering you our products and/or services. There may also be limits to the exercise of your rights, for instance when applicable laws or regulations require us to process your data, or when our legitimate grounds for the processing override your interests and rights.

9. Amendment

We keep our Privacy Policy under regular review and consequently, it may change at any time in the future.

We advise you to visit this website regularly to check for any amendments.

10. Contact

If you have any questions about how your Personal Data is processed or if you want to exercise the above rights, you may contact us by email at contact@zenopartners.com.