Cero Generation

Privacy and cookies

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  1. Introduction
    1. We are committed to safeguarding the privacy of our website visitors, individuals upon whom we carry out due diligence and the personnel of our customers and suppliers.
    2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
    3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
    4. This privacy policy is issued on behalf of the Cero Generation group of companies, so when we mention “Cero Generation”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Cero Generation group responsible for processing your data. Cero Generation Services Limited is the controller responsible for this website. For more information about us, see Section 18.
  2. The personal data that we collect
    1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
    2. We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, and/or postal address. The source of the contact data is you and/or your employer.
    3. We may process information relating to our customer relationships (“customer relationship data“). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
    4. We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
    5. We may process information that you provide when completing due diligence questionnaires for us (“due diligence data”). The due diligence data may include your name; previous names; address; nationality; date of birth; ID details; whether or not you are a public official or a politically exposed person plus details of any public officials or politically exposed persons you are associated with; details of your stance on and training you have had on sanctions, anti-bribery and corruption; your financial history and where your main trading bank account is located; details of criminal convictions you have had or any prosecutions or investigations you have been subjected to relating to misconduct, bribery, corruption, fraud, breach of sanctions, misrepresentation, tax evasion or similar; details of the goods and services you may provide to us; details of conflicts of interest you may have; and details of any sanctions lists that you may appear on. The source of the due diligence data is you
    6. We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
    7. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
  3. Purposes of processing and legal bases
    1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    2. Operations – We may process your personal data for the purposes of operating our website, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
    3. Relationships and communications – We may process contact data, customer relationship data, and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, and customer and supplier personnel, the maintenance of our relationships, and the proper administration of our website, services and business.
    4. Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
    5. Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
    6. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
    7. Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    8. Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    9. Legal compliance and vital interests – We may also process your personal data, including due diligence data, where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
    10. Personal data relating to criminal convictions and special categories of particularly sensitive personal information, such as information about your political opinions require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. In general, we will not process your criminal convictions data or particularly sensitive personal information about you. However, for those individuals upon whom we carry out due diligence, we may process information about your political opinions for reasons of substantial public interest, namely our regulatory requirements relating to unlawful acts and dishonesty, preventing fraud and suspicion of terrorist financing or money laundering. If this ground for processing your personal data is not available in the jurisdiction you are based in, then our legal basis for processing this personal data is your explicit consent. We may process your criminal convictions data as we are legally authorised to do so to meet our regulatory requirements relating to unlawful acts and dishonesty, preventing fraud and suspicion of terrorist financing or money laundering. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.
  4. Providing your personal data to others
    1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
    2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
    3. Your personal data will be stored on the servers of our hosting services providers: Google Cloud Platform.
    4. We may disclose your personal data to our suppliers or subcontractors as specified in the table below insofar as reasonably necessary for the purposes specified in the table below.
      Supplier/Sub-contractorPurpose
      MicrosoftDocument management and storage
      Mirus IT Solutions LimitedIT support 

      Local SEO UK/

      Commonality Ltd 

      		Website development/Updating, Hosting, Digital Marketing
      Exiger Canada IncPlatform through which we carry out third party due diligence
    5. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
  5. International transfers of your personal data
    1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
    2. We and our other group companies have offices and facilities in France, Germany, Greece, Italy, Poland, Spain and the United Kingdom. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.
    3. The hosting facilities for our website are situated in the European region. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.
    4. Microsoft is situated in various countries around the globe. Where appropriate, transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
    5. Exiger Canada Inc is situated in Canada. Transfers to Canada will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
    6. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
  6. Retaining and deleting personal data
    1. This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain your personal data as follows:
      1. contact data will be retained for a period of 6 years following the date of the most recent contact between you and us;
      2. customer relationship data will be retained for a period of 6 years following the date of termination of the relevant customer relationship;
      3. communication data will be retained for a period of 6 years following the date of the communication in question; and
      4. due diligence data will be retained for indefinitely following collection; and
      5. usage data will be retained for 1 year following the date of collection.
    4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  7. Security of personal data
    1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    2. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
    3. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
  8. Your rights
    1. In this Section 8, we have listed the rights that you have under data protection law.
    2. Your principal rights under data protection law are: 
      1. the right to access – you can ask for copies of your personal data;
      2. the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure – you can ask us to erase your personal data;
      4. the right to restrict processing – you can ask us to restrict the processing of your personal data;
      5. the right to object to processing – you can object to the processing of your personal data;
      6. the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
      8. the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
    4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
  9. Third party websites
    1. Our website includes hyperlinks to, and details of, third party websites.
    2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
  10. Personal data of children
    1. Our website and services are targeted at persons over the age of 18.
    2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
  11. Updating information
    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
  12. About cookies
    1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
    2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
    3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
  13. Cookies that we use
    1. We use cookies for the following purposes:
      1. personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: trp_language);
      2. security – we use cookies as an element of the security measures used to protect our website and services generally (cookies used for this purpose are: _gat);
      3. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: hu_consent).
      4. development – we use cookies to be able to implement or change our website’s content in real time (cookies used for this purpose are: elementor); and
      5. analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _ga, _ga_#, _gid).
  14. Cookies used by our service providers
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy. The relevant cookies are: collect, _ga, _gat_gtag_UA_225060073_1, _ga_FERVYVRRK8, _ga_S4WEZ1SRT8, _gid.
    3. We use Bamboo HR to provide us with Human Resources services. This service uses cookies for load-balancing, deliverance of website content and serving DNS connection for us as a website operator. You can view the privacy policy of this service provider at https://www.bamboohr.com/privacy-policy/. The relevant cookies are: _cfuvid.
    4. We use Hu-manity.co to help ensure that we configure our website in a manner which is mindful of your privacy preferences. This service uses cookies to store your preferences in relation to the use of cookies on our website. You can view the privacy policy of this service provider at https://hu-manity.co/privacy-policy/. The relevant cookies are: hu-session and hu-config.
  15. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
      1. https://support.google.com/chrome/answer/95647 (Chrome);
      2. https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
      3. https://help.opera.com/en/latest/security-and-privacy/ (Opera);
      4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
      5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
      6. https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our website.
  16. Cookie preferences
    1. You can manage your preferences relating to the use of cookies on our website by clicking on the cookie symbol on the bottom lefthand corner of this page.
  17. Amendments
    1. We may update this policy from time to time by publishing a new version on our website.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  18. Our details
    1. This website is owned and operated by Cero Generation Services Limited.
    2. We are registered in England and Wales under registration number 12272533, and our registered office is at 17th Floor HYLO, 103-105 Bunhill Row, London, EC1Y 8LZ  
    3. You can contact us:
      1. by post, to the postal address given above; or
      2. using our website contact form

We are Cero Generation, a leading solar energy developer working across Europe to deliver a net-zero future, for this and every generation.

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