Privacy Policy

Introduction
We understand that your privacy is important to you and that you care about how your personal data
is used and shared online. We respect and value the privacy of everyone who visits this website,
www.fromalphatozen.com (“Our Site”) and will only collect and use personal data in ways that are
described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our
Privacy Policy and Cookie Policy is required when you first use Our Site and you should read and accept
this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy
Policy, you must stop using Our Site immediately.
Definitions and Interpretation
In this policy, the following terms shall have the following meanings:
• Account
Means an account required to access and/or use certain areas and features of Our Site;
• Cookie
Means a small text file placed on your computer or device by Our Site when you visit certain parts of
Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are
set out in section 13, below;
• Cookie Law
Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations
2003;
• Personal Data
Means any and all data that relates to an identifiable person who can be directly or indirectly identified
from that data. In this case, it means Personal Data that you give to Us via Our Site. This definition
shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 OR EU
Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
• Information about us
Our Site is owned and operated by the Inemmo Limited.
Our Data Protection Officer is Daniel Jacobs, and can be contacted by email at da****@in****.com
by telephone on 0800 689 9110
Page 2 of 7
What does this policy cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites.
Please note that We have no control over how your data is collected, stored, or used by other websites
and We advise you to check the privacy policies of any such websites before providing any data to
them.
Your rights

  1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of
    Personal Data have been designed to uphold:
    • The right to be informed about Our collection and use of Personal Data;
    • The right of access to the Personal Data We hold about you (see section 12);
    • The right to rectification if any Personal Data We hold about you is inaccurate or incomplete
    (please contact Us using the details in section 14);
    • The right to be forgotten – i.e. the right to ask Us to delete any Personal Data We hold about
    you (We only hold your Personal Data for a limited time, as explained in section 6 but if you
    would like Us to delete it sooner, please contact Us using the details in section 14);
    • The right to restrict (i.e. prevent) the processing of your Personal Data;
    • The right to data portability (obtaining a copy of your Personal Data to re-use with another
    service or organisation);
    • The right to object to Us using your Personal Data for particular purposes; and
    • Rights with respect to automated decision making and profiling.
  2. If you have any cause for complaint about Our use of your Personal Data, please contact Us using
    the details provided in section 14 and We will do Our best to solve the problem for you. If We are
    unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority,
    the Information Commissioner’s Office.
  3. For further information about your rights, please contact the Information Commissioner’s Office
    or your local Citizens Advice Bureau.
    What data do we collect?
    Depending upon your use of Our Site, We may collect some or all of the following personal and nonPersonal Data (please also see section 13 on Our use of Cookies and similar technologies.
    • Salutation;
    • name;
    • date of birth;
    • gender;
    • business/company name
    • job title;
    • profession;
    • contact information such as email addresses and telephone numbers;
    • demographic information such as post code, preferences, and interests;
    • IP address;
    • web browser type and version;
    • operating system;
    • a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
    Page 3 of 7
    How do we use your Data?
  4. All Personal Data is processed and stored securely, for no longer than is necessary in light of the
    reason(s) for which it was first collected. We will comply with Our obligations and safeguard your
    rights under the GDPR at all times. For more details on security see section 7, below.
  5. Our use of your Personal Data will always have a lawful basis, either because it is necessary for
    Our performance of a contract with you, because you have consented to Our use of your personal
    data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may
    use your data for the following purposes: Providing and managing your Account;
    • Providing and managing your access to Our Site;
    • Personalising and tailoring your experience on Our Site;
    • Supplying Our products and services to you (please note that We require your Personal Data
    in order to enter into a contract with you);
    • Personalising and tailoring Our products and services for you;
    • Replying to emails from you;
    • Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any
    time via our website www.fromalphatozen.com under the ‘Contact Us’ section and send
    us a message or email in**@fr************.com
    • Market research, including product usage and transactional data.
  6. With your permission and/or where permitted by law, We may also use your data for marketing
    purposes which may include contacting you by email and/or telephone and text message with
    information, news and offers on Our products and services. We will not, however, send you any
    unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your
    rights and comply with Our obligations under the GDPR and the Privacy and Electronic
    Communications (EC Directive) Regulations 2003.4.
  7. Third parties whose content appears on Our Site may use third party Cookies, as detailed below
    in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that
    We do not control the activities of such third parties, nor the data they collect and use and advise you
    to check the privacy policies of any such third parties.
  8. You have the right to withdraw your consent to Us using your Personal Data at any time, and to
    request that We delete it.
  9. We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for
    which it was first collected. Data will therefore be retained for the period as stated within Our
    Retention Policy.
    How and Where Do We Store Your Data?
  10. We only keep your Personal Data for as long as We need to in order to use it as described
    above in section 6, and/or for as long as We have your permission to keep it.
  11. Your data will only be stored within the European Economic Area (“the EEA”) (The EEA
    consists of all EU member states, plus Norway, Iceland, and Liechtenstein)
  12. Data security is very important to Us, and to protect your data We have taken suitable
    measures to safeguard and secure data collected through Our Site.
  13. Subject to section 8.2, We will not share any of your data with any third parties for any
    purposes.
    Page 4 of 7
  14. We may sometimes contract with third parties to supply products and services to you on Our
    behalf. These may include payment processing, delivery of goods, search engine facilities,
    advertising, and marketing. In some cases, the third parties may require access to some or
    all of your data. Where any of your data is required for such a purpose, We will take all
    reasonable steps to ensure that your data will be handled safely, securely, and in accordance
    with your rights, Our obligations, and the obligations of the third party under the law.
  15. We may compile statistics about the use of Our Site including data on traffic, usage patterns,
    user numbers, sales, and other information. All such data will be anonymised and will not
    include any personally identifying data, or any anonymised data that can be combined with
    other data and used to identify you. We may from time to time share such data with third
    parties such as prospective investors, affiliates, partners, and advertisers. Data will only be
    shared and used within the bounds of the law.
  16. We may sometimes use third party data processors that are located outside of the European
    Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland,
    and Liechtenstein). Where We transfer any Personal Data outside the EEA, We will take all
    reasonable steps to ensure that your data is treated as safely and securely as it would be
    within the UK and under the GDPR.
  17. In certain circumstances, We may be legally required to share certain data held by Us, which
    may include your Personal Data, for example, where We are involved in legal proceedings,
    where We are complying with legal requirements, a court order, or a governmental
    authority.
    What Happens If Our Business Changes Hands?
  18. We may, from time to time, expand or reduce Our business and this may involve the sale
    and/or the transfer of control of all or part of Our business. Any Personal Data that you have
    provided will, where it is relevant to any part of Our business that is being transferred, be
    transferred along with that part and the new owner or newly controlling party will, under the
    terms of this Privacy Policy, be permitted to use that data only for the same purposes for
    which it was originally collected by Us.
  19. In the event that any of your data is to be transferred in such a manner, you will be contacted
    in advance and informed of the changes. When contacted you will not, however, be given the
    choice to have your data deleted or withheld from the new owner or controller.
    How Can You Control Your Data?
  20. In addition to your rights under the GDPR, set out in section 4, when you submit Personal
    Data via Our Site, you may be given options to restrict Our use of your data. In particular, We
    aim to give you strong controls on Our use of your data for direct marketing purposes
    (including the ability to opt-out of receiving emails from Us which you may do by
    unsubscribing using the links provided in Our emails and at the point of providing your details
    and by managing your Account. In particular, We aim to give you strong controls on Our use
    of your data for direct marketing purposes (including the ability to opt-out of receiving emails
    from Us which you may do by unsubscribing using the links provided in Our emails and at the
    point of providing your details and by managing your Account).
  21. You may also wish to sign up to one or more of the preference services operating in the UK:
    The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service
    (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you
    receiving unsolicited marketing. Please note, however, that these services will not prevent
    you from receiving marketing communications that you have consented to receiving.
    Page 5 of 7

Your right to withhold information

  1. You may access Our Site without providing any data at all. However, to use all features and
    functions available on Our Site you may be required to submit or allow for the collection of
    certain data.
  2. You may restrict Our use of Cookies.
    How can you access your Data?
    You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held).
    Under the GDPR, no fee is payable and We will provide any and all information in response to your
    request free of charge. Please contact Us for more details at gd**@In***********.com, or using the
    contact details below in section 14.
    Our use of Cookies
    Please note that by deleting our cookies or disabling future cookies you may not be able to access
    certain areas or features of our site.
    What are Cookies?
    Cookies are text files containing small amounts of information which are downloaded to your device
    when you visit a website. Cookies are then sent back to the originating website on each subsequent
    visit, or to another website that recognises that cookie. Cookies are useful because they allow a
    website to recognise a user’s device. You can find more information about cookies by visiting:
    www.allaboutcookies.org.; or www.aboutcookies.org
    How the Inemmo Limited Uses Cookies
    Cookies allow the Inemmo to recognise devices and track how our visitors use fromalphatozen.com.
    We use cookies that are essential for you to navigate fromalphatozen.com or provide you with basic
    website features. Data collected from some cookies helps us enhance the performance of
    fromalphatozen.com and offer you a better user experience. We will not use any of this data to
    identify you personally, it is used only to monitor and improve fromalphatozen.com. There are several
    types of cookies that are used to keep track of information needed by a site user as they travel from
    page to page within a website..
    Cookies on Inemmo Limited Sites and Microsites First-party cookies
    Cookies can be used to track internet activity after the user has left a website. These are normally
    facilitated by organisations external to the website being visited and are generally known as ‘thirdparty’ cookies. They usually have a long lifetime with several months being quite common. They are
    ‘harvested’ and ‘refreshed’ whenever the user visits a page where the same or a similar cookie is being
    used.
    Third-party cookies and microsites
    The domain specified in the cookie relates to the cookie’s owner (the “party”), who has set the cookie.
    fromalphatozen cookies will have the fromalphatozen.com and fromalphatozen.co.uk domain
    specified in a cookie.
    Page 6 of 7
    These are first-party cookies. fromalphatozen.com sets a number of cookies. These are used to analyse
    visitors’ browsing of fromalphatozen.com for future improvements and to provide certain useful
    functions such as storing your login details, if you are an Inemmo Limited member.
    The data is not used to identify individual members. A third-party cookie is set when you visit a site
    but the domain named in the cookie sent to your computer is not the same as the website. For
    example, if you visit fromalphatozen.com.com, you may visit the
    Other Third Party processing activities
    If you shorten our site URLs, for example on Twitter or Facebook, we may use services such as goo.gl,
    bit.ly, tinyurl.com and ow.ly to do so, and our site works with these to rebrand our URLs as a
    https://www.fromalphatozen.com.com/xxxxx link. Also our website sometimes offers features that
    allow users to share links with social networks and our site may shorten that URL using one of these
    services.
    If you shorten our site URLs, for example on Twitter or Facebook, we may use services such as goo.gl,
    bit.ly, tinyurl.com and ow.ly to do so, and our site works with these to rebrand our URLs as a
    https://www.fromalphatozen.com.com/xxxxx link. Also our website sometimes offers features that
    allow users to share links with social networks and our site may shorten that URL using one of these
    services. These services provide us with anonymised, aggregated statistics relating to the use of our
    shortened URL, for example by telling us how many times it has been clicked on. We do not have
    access to the IP address of your computer collected by these services or any other identifiable
    information about you. Nor do they have any access to data collected on our website. For more
    information on these services please see below:
    • Google urlshortener, goo.gl – Privacy policy
    • Bitly Enterprise, bit.ly – Privacy policy
    • TinyURL, tinyurl.com – Terms of use
    • Ow.ly urlshortener, ow.ly
    Google Analytics
    We currently use Google Analytics to measure and analyse visitor information related to our web site.
    For that purpose, your IP address, internet traffic data and data on your browser type and PC are
    collected using several cookies (_utma, _utmc, utmb, utmz):
    • _utma is used by Google Analytics to identify first-time site (‘unique’) visitors vs. returning
    visitors. It expires after two years
    • _utmz tracks source visits (the origin of the visit). It expires after six months.
    • _utmc identifies unique visitors vs. returning visitors but expires when you close your
    browser.
    • _utmb is used for general visitor tracking and expires after 30 minutes.
    Google may also transfer this information to third parties where required to do so by law, or where
    such third parties process the information on Google’s behalf. Google will not associate your IP
    address with any other data held by Google. For information on how to reject or delete this cookie.
    Please visit https://www.google.com/intl/en/privacypolicy.html for more information.
    Page 7 of 7
    Google Analytics
    Microsites are collections of webpages created as a discrete entity within a larger website. Microsite
    pages are usually related by content on a similar topic. They often have a different domain name from
    the parent website and content for microsites may be provided by specialist organisations.
    fromalphatozen.com hosts several microsites on our servers and links to many others hosted by our
    corporate partners. Inemmo does not control dissemination of third party cookies.
    Contacting us
    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at
    da****@fr************.com, or by telephone on 0800 689 9110. Please ensure that your query is
    clear, particularly if it is a request for information about the data We hold about you (as under section
    12, above)
    Changes to our Privacy Policy
  3. We may change this Privacy Policy from time to time (for example, if the law changes). Any
    changes will be posted on Our Site and you will be deemed to have accepted the terms of the
    Privacy Policy on your first use of Our Site following the alterations. We recommend that you
    check this page regularly to keep up-to-date.1. We may change this Privacy Policy from time
    to time (for example, if the law changes). Any changes will be posted on Our Site and you will
    be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site
    following the alterations. We recommend that you check this page regularly to keep up-todate.
  4. For the avoidance of doubt all policies relating to GDPR and/or data protection (whether
    referred to on the infonet, the Inemmo Limited website or otherwise communicated to the
    Inemmo Limited’s staff, members or non-members) are not contractually binding on the
    Inemmo Limited and may be withdrawn or amended at any time. They will be under ongoing
    review and will be replaced with the latest versions accordingly.

© 2021 Joy Maitland. All Rights Reserved, Joy Maitland Inc.