Data Privacy Statement
Your privacy is important to us. This privacy statement provides information about the personal information that we collect, and the ways in which we use that personal information.
This document declares the undertakings by Zeitfokus in relation to its handling of your data.
II. Data Collection
Zeitfokus undertakes to collect your data by means that are:
- legal; and
If you visit Zeitfokus' websites, your web-browser automatically discloses, and Zeitfokus’ webserver automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a webform, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a webpage within a domain (such as zeitfokus.de or zeitfokus.info). This data may or may not be sufficient to identify you.
If you disclose personal data to Zeitfokus in conjunction with an identifier such as your name or your credit-card details, Zeitfokus will collect your data. Moreover, any data that becomes available to Zeitfokus through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become your data.
Subject to the qualifications immediately below, Zeitfokus undertakes to collect your data from you and not from other parties. This undertaking is qualified as follows:
- where Zeitfokus reasonably considers that the protection of its financial interests requires that it gather your data from other sources, or from additional sources. This applies where Zeitfokus has a lending exposure to you, and seeks information about your creditworthiness;
- where Zeitfokus reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering your data from other sources. This applies to consumer profile data.
Where Zeitfokus collects your data from sources other than you, it undertakes:
- to do so only by legal means;
- to do so only with your consent; and
- to declare to you, what sources it uses, and under what circumstances.
Zeitfokus undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
III. Data Security
Zeitfokus undertakes to store your data in a manner that ensures security against unauthorized access, alteration or deletion, at a level corresponding with its sensitivity.
Zeitfokus undertakes to store your data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Zeitfokus undertakes to transmit your data in a manner that ensures security against unauthorized access, alteration or deletion, at a level corresponding with its sensitivity.
Zeitfokus undertakes to implement appropriate measures to ensure security of your data against inappropriate behavior by Zeitfokus’ staff-members and contractors. These include:
- training for staff in relation to privacy;
- access control, to limit access to your data to those staff and contractors who have legitimate reasons to access it;
- particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
- reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behavior;
- declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behavior
- clear communication of policies and sanctions; and
- processes to audit, to investigate and to impose sanctions.
IV. Data Use
Use refers to the application of your data by any part of Zeitfokus, or any staff-member or contractor of Zeitfokus in the course of their work.
Zeitfokus undertakes to use your data only for:
- the purposes for which it was collected;
- such other purposes as are subsequently agreed between Zeitfokus and you;
- such additional purposes as may be required by law. In these circumstances, Zeitfokus will take any reasonable steps available to it to communicate to you that the use has occurred, unless it is precluded from doing so by law; and
- such additional purposes as are authorized by law (in particular to protect Zeitfokus’ interests, e.g. if it believes on reasonable grounds that you have failed to fulfill your undertakings to Zeitfokus or have committed a breach of the criminal law).
Zeitfokus undertakes to use your data only if it has demonstrable relevance to the use to which it is being put.
Zeitfokus undertakes to use your data in such a manner as to consider the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
V. Data Disclosure
Disclosure refers to making your data available to any party other than Zeitfokus and you. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Zeitfokus undertakes to disclose your data only under the following circumstances:
- during business being conducted between you and Zeitfokus, where disclosure is necessary to a contractor, such as a transport company. Where your data is disclosed in this way, Zeitfokus undertakes to exercise control over Zeitfokus’ contractors to ensure that their actions are compliant with these terms;
- in other circumstances that are directly implied by the purpose agreed between You and Zeitfokus at the time of data collection or subsequently. Where your data is disclosed in this way, Zeitfokus undertakes to exercise control over Zeitfokus’ contractors to ensure that their actions are compliant with these terms;
- with your consent, or at your request;
- where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Zeitfokus will take any reasonable steps available to it to communicate to you that the disclosure has occurred, unless it is precluded from doing so by law;
- where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Zeitfokus believes on reasonable grounds that the disclosure of your data will materially assist in the protection of the life or health of some person), provided that Zeitfokus will apply due diligence to ensure that the exercise of the permission is justifiable.
In all cases, Zeitfokus undertakes to disclose only such of your data as is necessary in the particular circumstances.
VI. Data Retention and Destruction
Subject to the qualifications immediately below, Zeitfokus undertakes:
- to retain your data only, if it is consistent with its purpose; and
- to destroy your data when its purpose has expired, and to do so in such a manner that your data is not subsequently capable of being recovered.
This undertaking is qualified as follows:
- your data may be retained in Zeitfokus’ logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, your data will be destroyed in accordance with those cycles;
- your data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Zeitfokus:
- will take any reasonable steps available to it to communicate to you that your data is being retained, unless it is precluded from doing so by law; and
- will only retain your data while that provision is current, and will then destroy your data;
- your data may be retained beyond the expiry of its purpose if it is authorized by law (in particular to protect Zeitfokus’ interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Zeitfokus or have committed a breach of the criminal law). In these circumstances, Zeitfokus will only retain your data while that situation is current, and will then destroy your data.
VII. Access by You to Your Personal Data
Zeitfokus undertakes to provide you with access to your data, subject to only such conditions and processes as are reasonable in the circumstances. Zeitfokus undertakes to enable access:
- without unreasonable delay; and
- without cost.
Zeitfokus undertakes to establish and operate identity authentication protections for access to your data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved to provide you with access through a channel that you have previously registered with Zeitfokus (such as an email-address), but may impose more onerous procedures if you wish to use some other channel.
If you dispute some aspect of your data, Zeitfokus undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of your data.
- not to seek access for frivolous purposes, or unreasonably frequently; and
- to accept that deletion of some data may not be consistent with the provision of services by Zeitfokus to you.
VIII. Information about Data-Handling Practices
Zeitfokus undertakes to make information available to you about the way Zeitfokus handles your data:
- in general terms, in a readily accessible manner; and
- in more specific terms, on request.
Where your data is disclosed to a contractor, Zeitfokus undertakes to make information available to you on request about the way Zeitfokus’ contractors handle your data.
Zeitfokus undertakes to ensure that the information provided is meaningful, and addresses your concerns.
- not to seek such information for frivolous purposes, or unreasonably frequently; and
- to accept that the disclosure of excessive detail may harm the security of your data and Zeitfokus’ business processes, and may harm Zeitfokus’ commercial interests.
IX. Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Zeitfokus’ behavior in relation to these Terms, you undertake:
to communicate them in the first instance:
- to Zeitfokus only;
- in sufficient detail;
- through a channel made available by Zeitfokus for that purpose;
- to provide one or more channels for communications to Zeitfokus, which are convenient to users;
- to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Zeitfokus’ reference-code for the communication;
- to promptly provide a response to the communication, in an appropriate and meaningful manner.
You further undertake to not pursue Zeitfokus through any regulator or the media:
- until and unless Zeitfokus has had a reasonable opportunity to respond to the initial communication; and
- while Zeitfokus and you are conducting a meaningful dialogue about the matter.
Zeitfokus declares that its undertakings in these terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.
You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between you and Zeitfokus, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which Zeitfokus is domiciled or performed the relevant acts.
XI. Changes to These Privacy Undertakings
- not to unilaterally make any material change to these terms in a manner that reduces the protections for your data;
- to take all practicable steps to prevent any company that acquires this company or any of its relevant assets from materially changing the terms applicable to your data in a manner that reduces the protections for your data;
- where it is considering making changes to these terms, or creating more specific terms relating to specific services, to consult with appropriate representative and advocacy organizations;
- where it makes changes to these terms, to ensure that the differences between successive versions are readily accessible;
- to maintain all prior versions of these terms in such a manner that they are dated, and readily accessible.
Zeitfokus is a non-trading company that owns several subsidiaries.
Your data means data that is capable of being associated with you, whether it includes an explicit identifier such as your name or customer number. It encompasses all data that Zeitfokus is capable of correlating with you, using such means as server-logs and cookie-contents.
Your data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.
Consent means your agreement with an action to be taken by Zeitfokus. Consent may be express or implicit, but in either case must be informed and freely given.
XIII. Modification of Terms
Zeitfokus reserves the right to modify these Terms at any time. Except as otherwise stated herein, any change to these Terms is effective immediately after Zeitfokus publishes the new terms. Notice may or may not be given through e-mail, a posting on the site or any other means by which a User may obtain notice. User agrees to check the site periodically for changes to these terms. Any use of the site after changes have been made shall be deemed acceptance of those changed terms and/or conditions.
XIV. Contact Information
In the event of questions about access to your personal information or prospect information; our collection, use, management, or disclosure of personal information or prospect information; or this privacy statement, contact us at:
483 Green Lanes
London, England N13 4BS
Phone: +44 20 8068 9746