This Privacy Policy describes how nZeros Limited (“nZeros Limited”, “Controller”, “we,” “us,” or “our”), handles your personal information if you are the person, who uses our (“Website”) and provides us with personal information.

This Privacy Policy covers all types of data that we collect through our Website or other channels related to it (for example, through e-mails and inquiries sent to our customer support service).

Any information that is collected about visitors of the Website by us is referred to as “User information” or “Personal Information”.

nZeros Limited commits to protecting the personal information that you provide us with and we will take all reasonable actions to ensure that all such data remains intact. We take every measure to make sure that all your personal information is safe with us. As we act in our clients’ best interests, we do not conceal the fact that we process your personal data. nZeros Limited undertakes to protect your personal data and process it according to the applicable laws as follows:

  • The Personal Data (Privacy) Ordinance (Cap. 486) (hereinafter referred to as the “PDPO”), as well as various subsidiary laws issued in accordance with the same PDPO law;
  • The General Data Protection Regulation;
  • Any other legislation as amended from time to time or legislative act applicable in a particular case.

As a Controller, nZeros Limited provides control over personal data processing in accordance with this Privacy Policy. 

We can from time-to-time change, modify, add and/or delete parts of this Privacy Policy. We recommend that you occasionally return to this page for any updated information.

If you do not agree to the terms of this Privacy Policy, please refrain from using our Website. If you agree to our Privacy Policy, we will be glad to offer our services.

You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential for us to provide you with our services. You might not be able to obtain certain services if you choose to withhold information we have requested that is required for those services.

1. Contact Details

1.1. The Data Protection Officer within nZeros Limited is the designated person responsible for all issues connected with Data Protection and Confidentiality.

1.2. If you have any questions relating to this Privacy Policy, processing your personal data, exercising your rights or if you have any complaints, please contact us at legal

2. The type of personal information we collect

2.1. We gather personal data in cases where we have no opportunity to use anonymous or anonymized data.

2.2. Through interaction with you or through your interaction with us and our Website, we gather the following types (categories) of personal information:

Data that you provide to us, for example:

  • Personally identifiable information (first and last name, email address, telephone number) only if you choose to fill out a “Contact Us” form, found on the Website to email us directly;
  • Any data that you submit within your CV for a job opening, including your employment history, writing samples, and references;
  • Demographic information which indicates your age, gender, country;
  • Information from any research or surveys submitted by Website visitors within surveys (on a voluntary basis only) on various topics, including events and experiences, media consumption preferences and how we can improve our services;
  • Information on your visit of the Website, including but not limited to, traffic data, location data (country, city), etc.; 
  • Information obtained by us from publicly available sources, and information provided to us by or on behalf of your employer, other organizations, or generated by us in the result of provision of services;
  • Information from the content of messages you submit through any of the fillable forms on the Website, such as feedback and services reviews you write, as well as the content of your communications collected for the purposes of providing you with the services;

Information obtained by messaging with us through the Website, e-mails, phone, texts and other means of communication, including your complaints, interests, preferences, intentions, etc.;

We automatically collect certain data, even if you are simply using our Website and not using our services. This may include:

  • your IP address;
  • date and time when you accessed our Website;
  • software and hardware details;
  • browser that you are using;
  • information about the operating system of the device that uses our Website, for instance, the latest versions of apps and language settings;
  • data relating to your clicks, the pages showed to you and your response to information elements;
  • logs;

Some information is collected using cookies and/or similar tracking technology. You can learn more about the technologies that we use and the information collection policy in the section 10 of this Policy.

2.3. If you are using a mobile device, we may also receive the data that identifies it, device settings and features, malfunctions and other system activity. When you visit our Website, our system records by what means and through which websites you accessed our Website.

2.4. We don’t collect any specific categories of personal data about you (this includes your race or ethnicity, religious or philosophical beliefs, sexuality, sexual orientation, political beliefs, union membership, information about your health and genetic and biometric data). We also don’t collect any information about any possible criminal sentences and crimes committed by you. If there is any necessity from our side to collect any sensitive information, it will be regulated pursuant to a privacy processing agreement to be signed between you and nZeros Limited. Other than that, we kindly ask you not to submit any sensitive information. 

2.5. Providing us with false details about yourself is illegal, and you are responsible for ensuring that we always have the most relevant and reliable information about you. If you find an error in the information provided to us, you are obliged to update your personal details.

2.6. In cases where you are unable to provide us with your personal data required in accordance with the law and/or in accordance with the terms of the agreement that you enter into, we will not be able to enter into an agreement with you and give you the opportunity to use our services.

3. How we collect personal information

3.1. We collect personal information directly when you provide it to us, like for example:

  • When you request a proposal from nZeros Limited in relation to our services;
  • When you apply for a job opening posted on the Website;
  • When you offer to provide services to us;
  • When you provide information to us by filling in forms on the Website (i.e. registering for newsletters and updates, subscribing to nZeros Limited’s services or job openings list, etc.);
  • When you complete surveys that we use for research purposes;
  • When you send us you inquiry through “Contact us” form.

3.2. nZeros Limited may collect User Information from third parties or publicly available information, including through electronic data sources. However, this Policy only addresses what happens if you visit the Website and this Policy does not apply to information collected by nZeros Limited offline or through any other means or any third-party, including through any application or content that may link to or be accessible from or on the Website.

3.3. We collect your IP’s device when, as an anonymous web user, you click on an advertiser’s banner hosted by our platform or a textual tracking link hosted by our platform.

4. How we use personal information

4.1 We use your personal data for various purposes in accordance with the law. Your data can be used for the following reasons:

Services provision: We shall use your data to give you an opportunity to access our Website (and/or register on it) and to be able to use our service described in Terms & Conditions.  

Customer support: We provide support to our customers using various communication channels. Certain data about you, for example, information about your activity in using our services or your account data assists you with problem solving and responds to your enquiries/requests connected to the use of our services and other related questions.

Service improvement: We also use your personal data for analytical purposes. This is part of our work to improve Services offered to our users. These data can also be used for testing purposes, to solve issues and to improve the functionality and quality of our Services. We strive to optimize our Website so that users enjoy browsing it and so that it meets their expectations and remains user-friendly.

Legal purposes: We can use your data to comply with legal regulations, process and resolve legal disputes, launch an inquiry at the request of government bodies, fulfill law enforcement requests, and ensure compliance with other conditions imposed on the company by certain authorities.

4.2 We will also use your personal information for processing your job application, in particular to review your application for nZeros Limited’s job opening. We will also use your personal information where you give us consent in order to customize our services. For example, we use your language preference in order to provide a more personalized experience. This involves the use of cookies or similar technologies.

4.3 We will only process your personal data for the purposes set out in this Section 4 and where we are satisfied that:

  • you have provided your consent to us using the data in that way, or
  • our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to be able to carry out our business, improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy, or
  • perform obligations and exercise rights under a contract that we have with you.

5. Marketing communication

5.1. We will only be sending you updates on our services and news in case you have consented and
have provided your details for this purpose.

5.2. You may opt out from direct marketing emails any time by clicking on “unsubscribe” link in
nZeros Limited’s email or by requesting us to unsubscribe from a newsletter at: contact

5.3. Please note that even if you object to receiving direct marketing materials, we may from time
to time need to send you some important messages regarding our services, and these messages you cannot refuse.

6. Disclosure of your personal information

6.1. nZeros Limited may share your User Information with third parties if 1) required by law; 2) to
administer the relationship between nZeros Limited and you/your organization; 3) in case there is another legitimate interest.

6.2. Although unlikely, in certain instances we may be required to provide User Information in
response to a court order, subpoena, or government investigation. We may release certain User Information when we believe that such a release is reasonably necessary to enforce or apply our Privacy Policy, to abide by the laws, where applicable, or to protect the interests and/or safety of nZeros Limited, its employees or its clients. We may also share User Information in the event of a merger, restructuring, reorganization, dissolution or other sale or transfer of some or all of nZeros Limited’s assets, liquidation or similar proceeding, where applicable.

6.3. In case nZeros Limited shares User Information with third parties, such third parties will be
bound to use it only for the purposes for which we disclose it to them and in line with the consent that you have submitted with respect to your User Information and such third parties will be bound by the obligations related to User Information processing of the same level of data protection.

6.4. User Information will be shared with those employees, agents and third-party providers on a
need-to-know only basis and subject to non-disclosure undertaking.

6.5. We reserve the right, and you hereby expressly authorize us, to share User Information in the
cases listed above.

6.6. You may request from nZeros Limited the list and categories of your Personal data that are
shared with third parties at: contact

6.7. The Website may have links to other websites operated by other companies and not covered
by this Privacy Policy. We do not accept any responsibility or liability for other websites’ privacy policies.
nZeros Limited is not responsible for the privacy practices of any third-parties, and you should contact such third-parties directly to determine their respective privacy policies.

7. Security and storage of personal data

7.1. We store personal information on secure servers that are managed by us and our service

7.2. We will retain your personal data for as long as reasonably necessary for the purposes listed in
Section 4 of this Policy or until you address us with a request for deletion of your data.

7.3. In some circumstances we keep your personal data during a certain period to meet legal, tax or
accounting requirements.

7.4. We maintain a data retention policy for personal data in our care. Where your personal data is
no longer required we will ensure it is either securely deleted or made anonymous.

7.5. If you have questions regarding the specific period of storage of a certain personal data type
processed by us, you can contact us by using contact details specified in clause 1.2.

8. Control and deletion of your personal information

8.1. You have the right to make a request to access personal information we hold about you and to
request corrections of any errors in that data. To make an access or correction request, you can contact us by using contact details specified in clause 1.2.

8.2. We use your personal data based on your consent. You may revoke such consent at any time in
accordance with the applicable law. If you are against the processing of your personal data on the basis of legitimate interests and at the same time you don’t have a direct access to mechanisms that refuse data processing, you can contact us using contact details provided in clause 1.2. However, we reserve the right to store certain personal data that we need to comply with legal requirements.

8.3. You can also file a complaint with the supervisory authority, in particular, in the state of your
habitual residence, workplace or location of the alleged violation if you believe that personal data processing concerning your rights violates personal data safety laws and regulations.

Your rights in relation to your personal information

9.1. Under PDPO you have the following rights in relation to your personal information:

  • a right to ascertain whether we hold personal data relating to you;
  • a right to access your Personal Information as held by us (subject access request);
  • a right to receive a copy of certain Personal Information in machine-readable format;
  • a right to have inaccurate Personal Information rectified;
  • where we have specifically requested your consent to process your Personal Information and have no other lawful basis to process it, you have the right to withdraw this consent;
  • a right to have certain Personal Information erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your Personal Information has been unlawfully processed, or where erasing your Personal Information is required in accordance with a legal obligation (Right to be forgotten);
  • a right to object to processing where our lawful basis for processing it is that it is in our legitimate interests; but please note that we may still process your Personal Information where there are other relevant lawful bases or where we have compelling grounds to continue processing your Personal Information in our interests which are not overridden by your rights, interests or freedoms;
  • a right to request an explanation of the logic involved where we make decisions about you solely through automated means;
  • a right to complain to your national data protection supervisory authority;
  • a right to object to direct marketing, which can be done by opting-out of direct marketing either through your account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

Cookies Information

10.1. To offer you a full range of functions when you visit our website, recognize your preferences,
and make the use of our website more comfortable and convenient, we use “cookies.”

10.2. We use Web analytics service to analyze and monitor activity on the Website. The Web
analytics utilize cookies, which are files placed on the hard drive of your computer, tracking the way visitors use the Website.

10.3. We set the first-party cookies, which collect information like your language preference and
login information and third-party cookies, which are set by Web analytics and exist for marketing and
advertising purposes.

10.4. Certain User Information is collected through enabling cookies, i.e. browser type, operating
system type, network location (domain), IP (Internet Protocol) address and other similar information, as well as referrer data identifying the web pages you visited prior to and after visiting the Website and your
movement and activity within the Website, however, no personally identifiable information.

10.5. We use aggregated User Information to analyze and improve the design, use, and content of the

10.6. We may use other technologies such as Web beacons and flash cookies to track efficiency and
effectiveness of our communications and how the Website is used.

10.7. By using our Website, you agree to the use and storage of cookies on your computer or device.

10.8. You can generally view our website without cookies, but certain parts of the website may not
work properly or navigating be slower.

10.9. If you do not wish cookies to be stored on your computer or device, you can deactivate the
relevant option in the system settings of your browser. You can also delete stored cookies in the system
settings of your browser at any time.

10.10. More information on how to deactivate or delete cookies can be found here: However, please keep in mind that if you do not accept any
cookies this may restrict the functionality of our offerings.

10.11. The Website incorporates security to allow you to disabling/enabling cookies. You have the
ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of the Website if cookies are disabled.
Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.

11. Changes and Modification of Privacy Policy

11.1. We will need to change this policy from time to time in order to make sure it stays up to date
with the latest legal requirement. A copy of the latest version of this policy will always be available on this

11.2. If we modify this Privacy Policy, we will update the “Date Last Modified” and such changes will
be effective upon posting.

nZeros Limited Privacy Policy v1.0, effective date 21th June, 2022

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