Privacy Policy

ZENTO A/S Privacy Policy

Hi! We’re Zento. We put our members at the heart of what we do. We want to build long-lasting relationships based on transparency and trust. This privacy policy aims to give you information on how Zento and B4B Payments collects and processes your personal data through your use of this website, including any data you may provide through this website when you process payments, take actions relating to your account, communicate with our Client Managers or during the onboarding process. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

ZENTO A/S and B4B Payments is your Data Controller

For the B4B payments privacy please view these here: https://www.b4bpayments.com/prepaid/privacy/

B4B Payments is the Data Controller for financial services, which means they are responsible for your personal data processed in relation to your use of the products and services accessible via the Zento Platform. When you receive services via the Zento Platform they collect, process, use, and are responsible for certain personal data about you. When they do so, they are regulated under the applicable laws on the protection of personal data, privacy, and electronic communications, including but not limited to The Data Protection Act 2018 (the “DPA 2018”, the United Kingdom General Data Protection Regulation (the “UK GDPR”) and The Privacy and Electronic Communications Regulations (“PECR”) and the EU GDPR.

When we are a ‘Data Processor’

When using some of our services and products, B4B Payments is a Data Controller, which means B4B Payments process personal data solely for the purposes of providing the client Products and Services. When you engage with ZENTO A/S Products and Services, or those of our partners, that involves you providing your employee, customer, or other third-party personal data, ZENTO A/S will be acting as a Data Processor of that data. When ZENTO A/S act as a Data Processor. We will let you know if you are using ZENTO A/S Products and Services for which you are a ‘Data Controller’ and where you shall review and enter into a Data Processing Agreement (‘DPA’) with us. By using those services, you will be deemed to have read, reviewed, and agreed to our DPA with you.

Personal data we collect.

We collect personal data for a variety of reasons, including to meet our legal obligations, manage our operations, improve our business, and deliver our services and products to you. Below is a list of types of personal data that we may collect and use when you apply for, or use, any of our products or services.

Type of personal data	Description	Purpose
Contact	Your name, addresses, e-mail addresses, phone numbers and other ways in which to contact you	Managing our relationship with you or your business. Communicating with you about our and our business partners’ products and services. Delivering the ZENTO A/S Products and Services to you, including to facilitate your use of the different ZENTO A/S Services via single sign-on. Developing and carrying out marketing or business development activities.
Transactional	Details about the transactions you carry out and the payments to and from your accounts with us	Making and managing customer payments. Delivering our and our business partners’ products and services. Managing fees, charges and interest due on customer accounts. Collecting and recovering money that is owed to us.
Contractual	Details about the products or services we provide to you	Carrying out our obligations arising from and exercising our rights set out in our contracts. Collecting and recovering money that is owed to us. Operating our business in an efficient and proper way, including managing our financial position, business capability, planning, and audit.
Locational	Data we get about where you are. This may come from the IP address assigned to your mobile phone or computer when you connect to the internet. It may also include locations where you used your ZENTO A/S payment card or post codes.	Delivering our and our business partners’ products and services. Identifying, investigating, reporting and preventing fraud, security breaches, money laundering and other crime.
Behavioural	Details about how you use products and services offered on the ZENTO A/S Platform from us and other organisations	Studying how our Members use products and services from us and other organisations. Delivering more personalised user experiences to our Members. Developing and carrying out marketing or business development activities.
Technical	Details on the devices and technology you use, for example your website browser settings, marketing choices	Delivering our products and services to you. Delivering our and our business partners’ products and services. Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Developing and carrying out marketing or business development activities.
Communication	Any emails, calls or other communications you’ve sent to us or we’ve sent to you What we learn about you from communications between us	Investigating and responding to your enquiries, complaints and feedback.
Public and third-party records	Details about you that are in public records, such as the Electoral Register, Companies House or similar local databases, and data about you that is publicly available on the Internet. We also collect data about you which we receive from other companies, such as credit reference or fraud protection agencies like the CIFAS register.	Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Registering you with a ZENTO A/S account. Developing and carrying out marketing or business development activities.
Usage data	Data about how you use our products and services	Studying how our Members use products and services from us and other organisations Testing new products Managing how we work with other companies that provide services to us and our Members Managing how we work with other companies that provide services to us and our Members
Documentary data	Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driver’s licence, photographs or birth certificate.	Identifying, investigating, reporting and preventing fraud, money laundering and other crime. Complying with laws and regulations.
Consents	Any permissions, consents or preferences that you give us	So we know what your preferences are in regards to marketing, automated decision-making and profiling (where this activity is based on your consent), cookies and any other relevant processing activities that you can opt-out of. Developing and carrying out marketing or business development activities.
Special category data and criminal offence data	Categories of data defined as ‘special category’ or ‘sensitive’ by applicable laws, including personal data related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union members, genetic data, biometric data, health, sex life or sexual orientation. We may also process data about your criminal offence history. In particular, we may collect data related to your health (such as disability data), biometric data (photos of you) and racial or ethnic origin (how you identify your ethnicity).	Understanding our community and the type of Members we work with, including about ethnicity, gender and health. Operating our business in a proper way, including corporate responsibility.
Your customer or employee data	Any data that you provide us with about your employees or customers including contact details, personal details (e.g., name, date of birth, bank account information) in our capacity as your data processor.	Delivering our and our business partners’ products and services to you

How do we collect your data? We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Company, Contact, Financial and Transactional Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our services;
create an account on our website;
subscribe to our service or publications
use our services;
request marketing to be sent to you;
give us feedback or contact us for any reason.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Third parties or publicity available sources. We are also working closely with third parties (including, service providers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive and exchange information about you with them.

What we do with your data?

We will only use your personal data for the purposes mentioned in this policy. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract, we are about to enter into or have entered into with you.

Where we need to comply with our legal and/or regulatory obligations.

You have the right to withdraw consent to marketing at any time by contacting us.

How long will we keep your data?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

By law, we must keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for a period of 8 years after you cease being customers for tax and regulatory purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Internal transfers

We take the security of your data very seriously, and all your personal data will be kept according to strict safeguards and in compliance with the GDPR. We share your personal data within Zento A/S. Your data will be stored on cloud servers within the UK by B4B Payments.

Third Parties

External Third Parties

Service providers acting as processors based in the United Kingdom or the European Union provide IT, system administration, identification, and two-factor authentication services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom and the European Union who provide consultancy, banking, legal, insurance, and accounting services.
HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom, and the European Union who require reporting of processing activities in certain circumstances.
Third-party credit reference agencies, in circumstances where we may need to assess your creditworthiness.
Our partners such as Payment Card Solutions (UK) Limited co reg. 05941947, UAB B4B Payments Europe registered in Lithuania with company code 305539054 provides you with the necessary services, and Mambu GmBh co reg F1103R_HRB149780

Cookies and other tracking technologies

We may use cookies to distinguish you from other users of our products or services when you visit Our Website. This helps us provide you with a good experience, allows us to improve our products or services, keeps Our Website safe, and presents you with advertising content that is relevant to you. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device when you visit Our Website. Cookies send data back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies also make it easier for you to log in and use the ZENTO A/S Platform.

We may use the following cookies:

Strictly necessary cookies are required for the operation of our products or services (including, for example, cookies that enable you to log into secure accounts and use interactive features);
Analytical/performance cookies that allow us to recognize and count the number of visitors and users and see how they use our products or services (e.g., to help us improve the way our products or services work or are provided, by ensuring that users easily find what they are looking for);
Functionality cookies to help us recognize you when you return to Our Website (this enables us to e.g., personalize our content for you, greet you by name, and remember your preferences, such as choice of language or region)
Targeting cookies to record your visit to Our Website, the pages you have visited, and the links you have followed. We may use this data to make our products and services and the data displayed on it, which we reasonably think is more relevant to your interests. We may also share this data with third parties for this purpose. In some instances, with respect to targeting cookies, we act as joint controllers with third parties, such as social media platforms.

For more detailed information on what specific cookies we use, please read our cookie policy.

You can block or disable cookies by activating the setting on your website browser that allows you to refuse the setting of all or some cookies or through the banner on Our Website. All browsers provide tools that allow you to control how you handle cookies: accept, reject, or delete them. These settings are normally accessed via the ‘settings’, ‘preferences’, or ‘options’ menu of the browser you are using, but you could also look for a ‘help’ function or contact the browser provider. However, if you set your browser settings to block or disable all cookies (including essential cookies) you may not be able to access all or parts of the ZENTO A/S Platform for which we require the use of cookies.

How to withdraw your consent or opt-out of processing

You can withdraw your consent to our processing of your data at any time. Please contact us if you want to do so at [email protected]

This will only affect the way we use data when our basis for processing your data is your consent. See the section ‘Your Rights’ and more specifically your right to restrict the use of your data.

You may also opt out of some forms of data processing we are conducting, such as:

Marketing, including email, phone, and SMS marketing.
Social media and targeted marketing, including retargeting and curated audiences.
Non-essential cookie collection on Our Website. You may be unable to opt out of ‘necessary’ cookies as discussed above.
Non-essential profiling and automated decision-making, including those activities undertaken for marketing purposes.

If you withdraw your consent and/or opt out, we may not be able to provide certain products or services to you. If this is so, we will tell you. You then have the option to give us your consent again if you want to access our products or services.

Keeping your data accurate

We will use reasonable efforts to ensure that your personal data is accurate, complete, and up to date. Please ensure you notify us without undue delay of any changes to the personal data that you have provided to us by updating your details on the ZentoPlatform or by contacting us at the details provided in this Privacy Policy.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

To be informed.
Request access to your personal data.
Request correction of your personal data.
Request the erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

Your legal rights:

You have the right to:

Be informed about what personal data we hold and how we are using it. This information is contained within this privacy notice.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can do so, by making a ‘subject access request’ to us in writing.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You may always object to further use of your data for direct marketing purposes by clicking the “unsubscribe” button within marketing emails or by contacting us by writing to us at [email protected]. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy
Where our use of the data is unlawful but you do not want to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format free of charge and on request. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by emailing [email protected]

Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the European commission´s office. Contact details for the ICO can be found here:

https://commission.europa.eu/about-european-commission/contact_en

No fee is usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis

Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.

We will only collect and process your personal data in accordance with one of the below lawful basis:

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Our legitimate interests include:

Improving our service
Providing you with marketing information about our services
Providing you with customer support and administering your account
Providing you with information about related products and services offered by Zento
Providing you with information about related products and services offered by our commercial partners

Performance of Contract means processing your data where it is necessary for the performance of a contract we have with you or taking steps at your request before entering into a contract, such as providing you with a quote.

Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to, such as in response to a request by law enforcement or when investigating a civil claim.

Consent means processing your personal data where you have been given the option to explicitly consent to share your data with selected third parties for marketing purposes or to sign up for related products and services, and you have chosen to consent. This will be via a separate notice via Zento.app. We will never assume that we have your consent unless you have explicitly opted in, and you can withdraw your consent at any time by contacting us.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time to ensure that it remains accurate. Please check back from time to time for updates.

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