Privacy Policy

Version: May 2024 

1. Who

This Privacy Policy sets out how Zero-g DOO, North-Macedonia , its affiliates and subsidiaries and each of its directors, officers, employees and authorized representatives (hereinafter referred to as: “Zero-G”) handle personal data of website visitors, consumers, (employees of) customers and suppliers and other third parties (“user” or “you”). 

 

This Privacy Policy describes the types of personal information we collect, why and how we use the information, with whom we share it, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. 

2. Scope

2.1 The scope of this Privacy Policy is limited to processing activities to which the Data Protection Regulation and its national implementation acts apply.

3. Responsibility

3.1 We will only process personal data in accordance with the applicable privacy legislation and as described in this Privacy Policy.

3.2 The website includes links to websites of third parties. We are not responsible for the content of these websites, services provided by these third parties or their compliance with the applicable privacy legislation. For more information, we refer to their respective privacy policies and/or information sections (if available).

3.3 The partners we work with are sole data controllers and thus fully responsible for their own processing activities. Although we select our partners with great care, we do not have any influence on the way they process your personal data. For more information, we refer to their respective privacy policies and/or information sections (if available). 

4. How we obtain your personal data

We obtain your personal data in various ways:

  • We obtain information actively provided by you. For example, if you contact us or if you provide information to us in the course of our services. 
  • We obtain some information automatically when you visit our website. For example, we automatically obtain information about you via cookies when you visit our website. For more information on this, please see Article 6.
  • We also obtain information from third parties. For example, we may request information about your company from the Trade Register of the Chamber of Commerce or we may receive your personal data from our partners. 
  • We may perform analyses on personal data about you. The resulting data can also qualify as personal data about you. For example, we may analyze which web pages are visited most frequently.

5. Details of processing 

5.1 It depends on the processing activity, which personal data we process about you, for which purposes we do so and based on which legal ground this takes place. Please find an overview below.

Activity 

Categories of personal data

Legal ground(s) for processing and purposes for processing

Visiting our website / platform

  • Information obtained through the cookies and similar information we use (please see Article 6);
  • Your IP address;
  • Technical features, such as which browser you use and the resolution of your device screen;
  • From which page you came to the Zero-g website;
  • From which country you visited the website;
  • Whether you used functionalities of the website;
  • Which pages you visited;
  • Mobile device identifiers;
  • Social media identifiers;
  • Geo-location data.

We collect these personal data on the basis of your consent or, in case we are not legally required to obtain consent, on the basis of our legitimate interests, namely improving our online services. This is the case with regard to technical cookies necessary for the functioning of the website and several analytic cookies that are not used to treat you differently from other users. 

 

We process your personal data for purposes of (i) improving our website and/or app, (ii) being able to match your preferences, (iii) being able to provide you with consistent service across all your devices, (iv) enhancing our security and protecting your information and (v) enhancing your user experiences. 

Account data

  • your username, password, email address;
  • your profile name;
  • if you choose, your name, social media and other third-party affiliations, profile picture and any other information you include in “About me” or “Intro” fields;
  • telephone number (if used for two-factor authentication); and
  • language and location (IP location);
  • the use you make of our Services and the content you provide while doing so.

We process this personal data in accordance with the terms of our contract with you (where we need this information to provide Services to you) or to take steps at your request prior to entering into a contract.

 

We also process your profile data (excluding details which you specify as non-public) by making it available through our Services to third parties so they can find you and review your profile. Your profile will also be linked to any reports and other content you submit publicly through the Services, or privately through our program. We do this in pursuit of the legitimate interests of us, Finders and customers, in making it easy to find and connect with relevant Finders and other users through our Services.

Customer service or otherwise corresponding with you

  • Your name and/or business contact information such as job title, department, and name of the organization; 
  • Your e-mail address and telephone number (either private or business contact details);
  • The content of your message, for instance, a complaint or business inquiry.

We collect these personal data on the basis of your consent or, in case we are not legally required to obtain consent, as this is necessary for the performance of a contract or on the basis of our legitimate interests, namely carrying out our general business activities and providing customer service.

 

We process your personal data for the purposes of (i) following up on your questions, complaints, and claims, (ii) providing information with regard to products or services that are relevant to you, (iii) verifying your identity to make sure you are who you say you are, and (iv) enhancing our security and protecting your information. 

Carrying out administration activities and/or the business relationship 

  • Your name and business contact information such as job title, department, and name of the organization; 
  • Your e-mail address and telephone number (business contact details);
  • User names and passwords used to access our resources;
  • Financial information such as account information or information as listed in our customer reports (outstanding payments, payments made and payments received);
  • Content otherwise provided by you. 

We collect these personal data as this is necessary for the performance of a contract, on the basis of legal requirements, or on the basis of our legitimate interests, namely verifying your identity for reasons of security and carrying out our regular business activities. 

 

We process your personal data for the purposes of (i) carrying out our contract with you, (ii) establishing and maintaining a business relationship with you, (iii) carrying out activities for administration purposes, (iv) verifying your identity to make sure you are who you say you are, and (v) enhancing our security and protecting your information. 

Job – Applicants / Employees

  • Name, initials, titles, gender;
  • Contact information such as telephone number, e-mail address, and address;
  • Bank account number; tax number
  • Working experience;
  • Nationality, date & place of birth;
  • Data concerning followed education, courses, and internships;
  • Information on the nature and content of the current and previous employment and on its termination. 

We collect these personal data on the basis of your consent or, in case it is not legally required to obtain consent, as this is necessary on the basis of our legitimate interests, namely assessing your suitability regarding the application process.

 

We process your personal data for the purpose of (i) the assessment of suitability of the person concerned for a position that is or may become available, (ii) the handling of expenses incurred by the applicant, and (iii) internal control and company security. 

5.2 If and insofar your personal data is processed on the basis of legitimate interests, information can be obtained by you as to the so-called balancing test that was carried out to allow us to rely on this processing ground. Please find our contact details below. 

6. Cookies 

6.1 We use the following types of cookies: cookies (functional, analyses and marketing), pixel tags, web beacons, clear GIFs, JavaScript and device IDs.

6.2 Please see below an overview of the cookies that we use:

 

Name cookie

Purpose of the cookie

Validity period

Functional cookies

Domain preference

We use this cookie to know whether or not you are logged in so we can redirect you to the right part of the website.

 

Cloudflare Session

Cloudflare helps make pages in our website load faster and protects you against malicious online attacks. 

The information is deleted from your device when you close the browser.

PolyFill Session

PolyFill helps Zero-g to across different browsers and versions.

The information is deleted from your device when you close the browser.

Zero-g

We use this cookie to keep you logged in while using the service.  

The information is deleted from your device when you close the browser.

Google Analytics

Google Analytics helps us track what pages in Zero-g users visit in aggregate. We use it to optimize our marketing activities. 

 

Analytical cookies

Heap Statistics

Heap allows us to track how users use Zero-g, so we can improve the product and solve customer support issues. 

 

Amplitude Statistics 

Amplitude allows us to track how users use Zero-g, so we can improve the product and solve customer support issues. 

 

Visual Website Optimizer Statistics 

VWO allows us to test different changes we make to the site, so we can see if our changes are making a positive impact on the user experience.

 
 

New Relic Statistics

New Relic allows us to track how users use Zero-g, so we can improve the product and solve customer support issues. 

 

Fullstory Statistics 

FullStory captures video of user sessions on Zero-g.com so we can give better customer support and inform product improvements. 

 

Delighted Statistics 

Delighted allows us to survey users, so we can receive feedback and improve the user experience. 

 

DoubleClick Marketing

We use DoubleClick to acquire users for our service, such as ads on Google search results. We do not display ads for any services besides our own. 

 

Marketing cookies

Facebook Pixel Marketing

We use the FB Pixel to acquire users for our service, such as ads on the Facebook feed. We do not display ads for any services besides our own. 

 

Tracking Cookies

   

6.3 Please note that if you refuse certain cookies, this may reduce the functionality of some parts of our website.

7. Sharing with third parties

7.1 For the provision of our services we share your personal data on a strictly need-to-know-basis with subcontractors and service providers involved, such as: software providers, carriers, e-commerce platforms, retailers, insurance companies, authorities,hosting and payment providers. In addition, we may share your personal data with persons authorized to this end, employed or engaged by a data processor of Zero-g or affiliated companies of Zero-g, involved in the processing of data, on a need-to-know basis (accounting and auditing firms, insurance and payroll companies and tax institutions).

7.2 We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena.  In that case, your personal data may be shared with competent authorities, such as the authorities of the country of transit or destination for customs clearance as far as required by the laws of the respective country. We attempt to notify users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. 

7.3 We also reserve the right to transfer information about you to a successor organization if, for example, we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner consistent with this policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. 

8. Security

8.1 We take appropriate organizational and technical security measures to protect your personal data and to prevent misuse, loss or alteration thereof. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who need to have access in view of their work/services. Also, the aforementioned persons involved are bound by a confidentiality obligation, either in their employment agreements or (data processing) agreements.

8.2 Examples of technical security measures taken by us are: 

a. technical control of the authorizations (as limited as possible) and keeping log files;

b. management of the technical vulnerabilities (patch management);

c. keeping software up-to-date (e.g. browsers, virus scanners and operating systems);

d. making back-ups to safeguard availability and accessibility of the personal data;

e. automatic erasure of outdated personal data;

f. encryption of personal data;

g. provide secure storage facilities for end-users (e.g. file server storage).

8.3 Examples of organizational security measures taken by us are: 

a. assign responsibilities for information security;

b. promote privacy and security awareness among new and existing employees;

c. establish procedures to test, assess and evaluate security measures periodically;

d. check log files regularly;

e. using a protocol for handling data breaches and other security incidents;

f. conclude confidentiality, data processing and data protection agreements;

g. assess whether the same objectives can be achieved with less personal data;

h. provide access to personal data to as few people within the organization as possible; and

i. define the decision-making and underlying considerations per processing.

9. Retention periods 

9.1 If you are a(n) (employee of a) customer or supplier, we store your personal data for administration purposes and in order to maintain a business relationship with you. General information regarding our business relation will be stored for a period of 2 years after the end of the business relationship. Financial and administration information will be stored for 7 years after the year of relevance on the basis of our statutory retention obligations under North Macedonian law.

9.2 If you contact us through the website, your information will be stored for as long as reasonably necessary to handle your request, question or comment, with a maximum of 12 months after our last moment of contact. The retention periods of the different cookies we use is included in Article 6. 

9.3 If you apply for a position within our organization, we will store the information provided by you for a period of 4 weeks after the end of the application procedure. You may request us to store your personal data for a prolonged period of 1 year after the end of the application procedure. You may also request us to delete your personal data immediately after the end of the application procedure or at any time during the storage period. 

10. Your rights (incl. the right to object)

10.1 In relation to our processing of your personal data, you have the below privacy rights.

a. Right to withdraw consent: In so far as our processing of your personal data is based on your consent (see above), you have the right to withdraw consent at any time. 

b. Right of access: You have the right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you (but not necessarily the documents themselves). We will then also provide you with further specifics of our processing of your personal data. 

c. Right to rectification: You have the right to request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

d. Right to delete: You have the right to request delete your personal data. This enables you to ask us to delete or remove personal data where: (i) the personal data are no longer necessary, (ii) you have withdrawn your consent, (iii) you have objected to the processing activities, (iv) the personal data have been unlawfully processed, (v) the personal data have to be erased on the basis of a legal requirement, or (vi) where the personal data have been collected in relation to the offer of information society services. We do not have to honour your request to the extent that the processing is necessary: (i) for exercising the right of freedom of expression and information, (ii) for compliance with a legal obligation which requires processing, (iii) for reasons of public interest in the area of public health, (iv) for archiving purposes, or (v) for the establishment, exercise or defence of legal claims.

e. Right to object: You have the right to object to processing of your personal data where we are relying on legitimate interests as processing ground (see above). Insofar as the processing of your personal data takes place for direct marketing purposes, we will always honour your request. For processing for other purposes, we will also cease and desist processing, unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or that are related to the institution, exercise or substantiation of a legal claim.

f. Right to restriction: You have the right to request restriction of processing of your personal data in case: (i)  the accuracy of the personal data is contested by you, during the period we verify your request, (ii) the processing is unlawful and restriction is requested by you instead of erasure, (iii) we no longer need the personal data but they are required by you for the establishment, exercise or defence of legal claims, or (iv) in case you have objected to processing, during the period we verify your request. If we have restricted the processing of your personal data, this means that we will only store them and no longer process them in any other way, unless: (i) with your consent, (ii) for the establishment, exercise or defence of legal claims, (iii) for the protection of the rights of another natural or legal person, (iv) or for reasons of important public interest 

g. Right to data portability: You have the right to request to transfer your personal data to you or to a third party of your choice (right to data portability). We will provide to you, or such third, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies if it concerns processing that is carried out by us by automated means, and only if the our processing ground for such processing is your consent or the performance of a contract to which you are a party (see above). 

h. Automated decision-making: You have the right not to be subject to a decision based solely on automated processing, which significantly impacts you (“which produces legal effects concerning you or similarly significantly affects you”). In this respect, please be informed that when processing your personal data, we do not make use of automated decision-making.

i. Right to complaint: In addition to the above mentioned rights you have the right to lodge a complaint with your local supervisory authority. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us beforehand.

10.2 The exercise of the abovementioned rights is free of charge and can be carried out by e-mail via the contact details displayed below. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request.

10.3 We may request specific information from you to help us confirm your identity before we comply with a request from you concerning one of your rights.

10.4 We will provide you with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. We will notify you of such an extension within one month of receipt of the request. The applicable privacy legislation may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

11. Contact details

11.1 If you have any questions or comments about this policy, if you would like us to update information we have about you or your preferences or if you would otherwise carry out your rights, you may contact us using the information below. Please make all inquiries or requests regarding your information in English so we can respond to and resolve requests.

 11.2 Please do not hesitate to reach out: Zero-g DOO, Kochani, North Macedonia, via email: privacy(at)zero-g.dev. Given its size and scope, Zero-g does not have a designated DPO.

12 Miscellaneous 

12.1 Zero-g is entitled at all times to delete your personal data without notice. In such a case, Zero-g owes no compensation to you as a result of the termination of the account.

12.2 If provisions from this Privacy Policy are in conflict with the law, they will be replaced by provisions of the same purport that reflect the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.

12.3 Zero-g reserves the right to change this Privacy Policy on a regular basis. Where required, Zero-g will inform you of updates made to this Privacy Policy. The current version is always available on our website.  

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