Privacy Policy

Marketing & Website Users

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

• Data controller: Zensai International ApS
• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us through our Freemium (Free Trial), Contact Us, Get a Demo, Partner and Quotation forms or by signing up for our Free Guide and newsletter and
  • from your use of our website, using cookies, and
  • occasionally, from third parties.
• Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), VAT number (if applicable).
• How we use your information: for administrative and business purposes (particularly to contact you to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyze your use of our website, and in connection with our legal rights and obligations.
• Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
• Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
• How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
• How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
• Use of cookies: we use cookies on our website including essential, functional, and analytical. For more information, please visit our cookies policy here.
• Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the following countries: United States, we will only do so if you yourself are based outside the European Economic Area. Where we do so, we will ensure appropriate safeguards are in place.
• Use of automated decision making and profiling: we do not use automated decision making or profiling.
• Your rights in relation to your information
  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • to complain to a supervisory authority
• Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is Zensai International ApS, Mariane Thomsens Gade 4B, 5, Aarhus, 8000, Denmark.

You can contact the data controller by writing to Zensai International ApS, Mariane Thomsens Gade 4B, 5 , Aarhus, 8000, Denmark or sending an email to [email protected].

If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

Web server log information

Our website is running in the Microsoft Cloud , the privacy policy of which is available here. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and Microsoft’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we Microsoft have a legitimate interest in using your information for the purposes of ensuring network and information security.

Cookies

This website uses cookies. We use cookies to content and ads, to provide social media features and to our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website.

Cookies are small text files that can be used by websites to make a user’s experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Microsoft 365 located in the United States. Their privacy policy is available here.

Emails you send us will be stored outside the European Economic Area on Microsoft’s servers in The United States. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Contact Us Form

When you contact us using our Contact Us Form, we collect we collect your name, email address, phone number, company name, country and IP Address. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as: job function, state, preferred platform, approx. number of learner, timeframe for purchase, and the option to subscribe to our newsletter. We also collect any other information you provide to us in the comments field when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

HubSpot Marketing Forms are used on our website and will submit info provided by the user to HubSpot. Their privacy policy is here.

A copy of the message is submitted to our email server provided by Microsoft Office 365 located in the United States. Their privacy policy is available here.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider and stored in the United Kingdom & Denmark.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Transfer and storage of your information

Information you send us by post is stored in respective countries where mail are sent to, so this could be Denmark, Germany, USA, UK, Australia & Poland. 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Contact Us Form

When you contact us using our Contact Us Form, we collect your name, email address, phone number, company name, country, comment and IP Address. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as: job function, state, preferred platform, approx. number of learner, timeframe for purchase, and the option to subscribe to our newsletter. We also collect any other information you provide to us in the comments field when you complete the contact form.

Newsletter

When you sign up for our newsletter on our website or opt to receive our Free Guide, we collect  your name and email address and IP Address.

Get a Freemium (Free Trial)

When you sign up for our Freemium (Free Trial) on our website, we collect  your name, email address, phone number, company name, country, state, approx. number of users, comment, newsletter option and IP Address.

Get a demo 

When you request a demo version, we collect your name, email address, phone number, company–name, product of interest, country, state, approx. number of Users, optional comments, newsletter option and IP Address. 

Become a Partner

When you sign up to become a Partner, we collect your name, email address, phone number, job function, department, company name, website, city, country, number of employees, competencies and qualifications, short company description, product of interest, how did you hear about us, newsletter option and IP Address.

Request a Quote

When you request a quote, we collect your name, email address, phone number, job function, company name, country, state, type of organisation, approx. numbers of users, optional comments, newsletter option and IP Address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, both Microsoft Dynamics 365, HubSpot & SalesLoft and Microsoft Exchange Online for sending mails related to Marketing users –  mailing list provider located in the United States.

Information you submit to subscribe for our e-newsletter and other contact forms will be stored outside the European Economic Area on our third party mailing list & service–provider’s servers in the United States. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area. 

For more information about our third party mailing list & service-providers please see their privacy policy which is available here: Data protection and privacy – Dynamics 365 Customer Insights | Microsoft Learn, HubSpot Privacy Page & SalesLoft Privacy Page

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf.

• Telephone providers (United Kingdom, Germany, Poland, Romania, Australia, Denmark & United States),
• Email provider (USA),
• Mailing list provider (USA),
• Web developers (Denmark, Romanian & Poland),
• Hosting provider (USA).
• Marketing & Customer Relations Management providers (Denmark/EU & USA) 

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc., HotJar and Sleeknote.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page:
https://www.google.com/policies/privacy/partners/

We use cookies to collect anonymous information about users visits to the website e.g. the number of visits, the average time spent on the website, and which pages have been read. The purpose is to segment the users of the website demographically and geographically to provide us with the opportunity to structure and understand our target group with the purpose of adjusting our online advertisement.

We use third-party cookies from AccuRanker which are used for information about whether you signed up for e.g. the newsletter, if you are in a new session and which website let you to our website. Read more about Accuranker here. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service
(https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants and business partners. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are Ernst & Young P/S, Vaerkmestergade 25, PO box 330, 8100 Aarhus C. Their privacy policy is available here.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

A list of our business partners can be found here. Please visit their own individual websites to see their Privacy Policy.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business effectively.

Legal basis for processing: necessary to perform a contract [or to take steps at your request prior to entering into a contract] (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example because of the services or information you have requested.

We do not display the identities of [all of] the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of Denmark or if they have been integrated into the Danish legal framework (for example in the form of an international agreement which the Denmark has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the Danish’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 24 further month(s) after which point we will delete your information.

Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to information;
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website
• only transferring your information via closed system or encrypted data transfers

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Zensai operates as a global business and may store, transfer, or process your data in a country outside your jurisdiction, including countries outside the European Economic Area (EEA). However, we have taken appropriate safeguards with respect to the protection of your privacy, fundamental rights, and freedoms. For example, if we transfer personal data from the EEA to a country outside it, such as the United States, we will implement an appropriate data transfer solution such as entering into EU standard contractual clauses with the data importer or taking other measures to provide an adequate level of data protection under EU law.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by raising a Subject Access Request either by writing a letter to Zensai International ApS, Mariane Thomsens Gade 4B, 5, Aarhus, 8000, Denmark or a mail to [email protected]:

• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
• https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Relevant information you can provide raising a Subject Access Request towards Zensai?

• A clear label for your request (eg use ‘subject access request’ as your email subject line or a heading for your letter);
• The date of your request;
• Your name (including any aliases, if relevant);
• Any other information used by the organisation to identify or distinguish you from other individuals (eg customer account number or employee number);
• Your up-to-date contact details;
• A comprehensive list of what personal data you want to access, based on what you need;
• Any details, relevant dates, or search criteria that will help the organisation identify what you want; and
• How you would like to receive the information (eg by email or printed out).

Zensai will answer Subject Access Request within 30 days.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected]

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.]

Copyright

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Recruitment Privacy Notice

At Zensai, protecting your personal data is a top priority. This notice outlines how we collect, use, and safeguard the information you provide during the recruitment process.

Data Protection Principles

Zensai complies with data protection laws and principles, ensuring that your data will be:

• Used lawfully, fairly, and transparently.
• Collected only for valid purposes that we have clearly explained to you and not used in ways incompatible with those purposes.
• Relevant to the purposes we have informed you about and limited to those purposes only.
• Accurate and kept up to date.
• Retained only as long as necessary for the specified period.
• Kept secure.

1. Collection of Personal Data

When you apply for a position at Zensai, we collect personal data directly from you or through our partners, depending on the type of recruitment. This information is essential for us to contact you and evaluate your suitability for the vacant position. Information provided to us will only be used to consider your application and in connection with subsequent employment.

To protect your privacy, we advise against including sensitive information such as your social security number, racial or ethnic background, religious beliefs, trade union membership, sexual orientation, or health information in your application.

This notice outlines the types of information we process about you when you apply for a position at Zensai and how we handle that data.

1.1. Types of Personal Data

We may collect and process the following types of personal data:

• Contact information such as name, email address, and phone number.
• Photo obtained as part of the CV.
• Information contained in the application, cover letter, curriculum vitae, and any attachments.
• Details of your qualifications, skills, experiences, educational background, and employment history.
• Relevant information published on social networks and from the internet (related to your professional life) to confirm the accuracy of the statements presented by you during recruitment.
• Background checks for security reasons include verifying your education, employment history, and any criminal records.
• Results of personality assessment, skills assessments, or tests, if completed as part of the recruitment process.
• References from previous and/or current employers that you have provided in your application or which we obtain about you from former employer.

We may also collect personal data about you from third parties, including:

• Recruitment agencies
• References provided by former employers
• Employment background check providers
• Criminal records checks

If we seek information from these third parties, we will inform you accordingly.

1.2 Purpose of Processing Your Data

We process your data to determine your suitability for the position based on Article 6(1)(b) and Article 6(1)(f) of the General Data Protection Regulation (GDPR). For national identification numbers, we use Article 87 of the GDPR.

1.3 Easy Apply – Third Party Platforms

We offer the option to apply for positions using third-party platforms, such as LinkedIn, through their “Easy Apply” feature. When you choose to apply via a third-party platform, the data you have provided to the third-party platform (such as your profile information, resume, and contact details) will be shared with us. The third-party platform acts as a data controller for the information you submit on their platform, and their privacy policy governs the handling of your data on their site.

Once your data is transferred to us from the third-party platform, we become the data controller for that information. We process this data in accordance with our recruitment privacy policy to determine your suitability for the position and to manage our recruitment process. This includes using your data to assess your qualifications, contact you for interviews, and potentially offer you employment.

1.4 Application Review Process

Our applicant evaluation process involves both automated and manual procedures conducted by our recruiting team. We use screening questions to verify that candidates meet the minimum requirements for the position, focusing on criteria such as academic background, experience, visa status, and language proficiency.

Applicants who do not meet these criteria may be automatically disqualified at this stage. After the automated screening, our recruiting team manually review applications to select candidates for job interviews.

Upon successfully concluding the recruitment process, we may store your personal data for future employment opportunities or other contractual relationships, in compliance with applicable legal regulations. We process general personal data and may also process sensitive personal data, including civil registration numbers and information about criminal records, as required.

1.5 Use of AI – Automated decision-making

Our recruitment processes occasionally utilize automated decision-making, such as confirming that you meet the minimum statutory requirements for a job. If automated decision-making prevents you from continuing with your application, you may request a review of the decision in accordance with your statutory rights under relevant data protection legislation by contacting us before the published closing date.

Additionally, we use Artificial Intelligence (AI) technologies to enhance and create job postings. We are committed to ensuring that the use of AI in creating job posts is transparent and fair. Our recruitment team review and approve all AI-generated content to ensure it accurately reflects job requirements and organizational needs.

1.6 Job Interviews

During the recruitment process, we conduct job interviews focusing on both your professional and your personal qualifications, the job content, and our business as a workplace. We will make a note of some of the information disclosed during the interview(s) for the purpose of the final evaluation of the applicants for the position. We will only use relevant information when determining whether to offer you a job.

We use Article 6(1)(b) and Article 6(1)(f) of the General Data Processing Regulation as the legal basis for processing. It is necessary for us to process such information in order to determine whether you are the right candidate for the position.

1.7 Personality Assessments

For certain positions, you may be invited to take a personality analysis and/or a logical test.

The purpose of the test is to evaluate your qualifications as a potential employee and to consider whether your profile suits our business and the specific position. The test will never stand alone but will be part of the general basis for selecting the right candidate for the position.

We always consider whether it is relevant that you take such a test in relation to the relevant position.

The legal basis for processing is our legitimate interests in assessing whether you are the right candidate for the position, cf. Article 6(1)(f) of the General Data Protection Regulation.

1.8 Test Assessments

As part of our recruitment process, you may be asked to complete tests or assessments. These evaluations are designed to evaluate your skills and problem-solving abilities, ensuring they match the requirements of the position you are applying for.

The tests and assessments may be conducted online or in person and could include real-time coding exercises, algorithm challenges, or other tasks relevant to the role. The results of these assessments will be considered alongside other information provided during the recruitment process to make an informed decision about your suitability for the position.

1.9 References

We obtain references for all positions, to check if the information you have provided us with during the recruitment process is correct. If we decide to obtain references from one or more of your previous employers, we will document that we have spoken with a referee. Before we obtain information about you from a former or current employer, we always ask for your consent.

1.10 Work and Residence Permit

For employees with citizenship other than the country you apply for a job in, it is a requirement for employment that Zensai have a valid work and residence permit. In order to ensure this, we may ask for a copy of your passport in connection with the employment.

If your citizenship requires you to have a valid work and residence permit, or other necessary documents which legalize your stay and work legally in Europe, in order to work legally in the country, we will also request a copy of your work and residence permit from you. We will obtain these when you are employed and when they are to be extended.

We check and process the information about your work and residence permit based on Article 6(1)(c) of the General Data Protection Regulation, as we are obligated to ensure that you have a valid work and residence permit.

1.11 Criminal Background Checks

For certain positions, Zensai may require a criminal background check as part of the recruitment process to ensure the safety and security of our employees, clients, and operations.

Whether a criminal background check is necessary will be determined based on a case-by-case evaluation, considering the specific requirements of the role and access to proprietary information, weighing the relevance and appropriateness of obtaining such information.

The legal basis for this processing is your explicit consent (Article 6(1)(a) and Article 9(2)(a) of the GDPR) or compliance with legal obligations (Article 6(1)(c) of the GDPR).

Before conducting a background check, we will seek your consent and provide detailed information about the process. The scope of the background check will be appropriate to the nature of the position, and we will handle all information with the utmost confidentiality and respect for your privacy.

1.12 Equal Employment Opportunities

At Zensai, we are committed to fostering an inclusive and diverse workplace. As a proud Equal Employment Opportunity (EEO) employer, we strive to maintain a work environment free from discrimination and harassment. Our employment decisions are based solely on business needs, job requirements, and individual qualifications, irrespective of race, color, religion, gender, sexual orientation, age, marital status, disability, or any other status protected by applicable laws and regulations.

We process your personal data under Article 6(1)(c) of the GDPR, which permits processing when necessary for compliance with legal obligations. This ensures our recruitment practices uphold the principles of equal opportunity and non-discrimination.

2. Retention Period

When you are offered the position at Zensai, your application as well as additional relevant personal data collected in connection with the recruitment process, will be stored with us.

If you are not offered the position, we will retain your application and any additional personal data collected in connection with the recruitment process for a period of 6 months, unless you have given your consent to a longer retention of such personal data. In case you want us to keep your data for 12 months, please send us a confirmation by mail.

The purpose of the storage is to document the recruitment process and the reason for not offering you the position.

3. Consent Withdrawal

You may revoke any consents you may have given at any time as part of our recruitment process. Revocation of your consent might influence the future processing of your personal data but will not affect the lawfulness of the processing based on the consent prior to the revocation. If you wish to revoke your consent, you may contact us at: [email protected].

4. Access to Personal Data

You have the right to request access to your information and at any time choose to have your data deleted by contacting [email protected].

Platforms & Services users

This privacy policy relates to the use of platforms and services delivered by:
Zensai International ApS
Mariane Thomsens Gade 4B, 5
8000 Aarhus
Denmark
In this document referred to as “Zensai” / “we” / “our” / “us”.
We are committed to protecting and respecting your privacy as a user of our platforms and services. You can read more about how we approach this in the sections below.

Purpose of this Privacy Policy

Your organization has entered into an agreement with Zensai (“Agreement”) to grant you access to the Zensai platforms & services (“Platform”) to make training and/or other content available for you or otherwise use the Platform. This Privacy Policy sets out how we collect and process your personal data.
References in this Privacy Policy to “your organization” shall refer to the entity who has entered into the Agreement with us. You will typically be an employee, officer, contractor, or consultant of an Zensai client.

Our status and responsibilities

Your organization is the data controller for the purposes of personal data processed under this Privacy Policy. Zensai will process your personal data on behalf of your organization and in accordance with its lawful instructions.
The information you provide to Zensai and/or upload to the Platform (whether or not it constitutes personal data) will also be governed by the Agreement.
Access to your and your organizations data is governed by your organization as data controller.
Information for your organization about data handling and security in relation to Platform and Services provided by Zensai is available online in our Trust Center, including our general statement on GDPR and Customer user data processing.
Where Zensai acts as a data controller; for example, in cases where you receive marketing communications from us, our Privacy Policy regarding Marketing & Website Users will apply.
If you should wish to contact us, please find information on how in the Contact Section below.

Personal data we collect and process

When your organization and you make use of our platform, we will collect and process certain information about you:

Information you provide

You may give us information about you:
When you use the Platform and services’s features – for instance, but not only, when you sign up for, complete or rate training
This information may include your: Microsoft 365 profile information, name, company email address, company telephone number, job title, department, primary office location, country, city, manager, and your training activities, results and records.
If you contact or correspond with us (for example via any support function made available by us), we may keep a record of that correspondence (either directly or through our service providers).
This also applies to any comments, opinions and/or feedback you provide to us regarding the Platform & services, for example during any product trials, tests, surveys, customer fora or research panels that you may participate in.

Information your organization provides

Your organization may give us information about you: 
When they create a user profile for you to be able to access and use the Platforms & services under the Agreement (whether on a trial or full basis), to enable us to contact you for purposes relating to your and your organization’s use of the Platforms & Services, to troubleshoot any issues relating to your or your organization’s use of the Platforms & Services, that is reported to us, and otherwise in the course of your organization’s use of the Platforms & services. 
This information may include your: Microsoft profile information, name, company email address, company telephone number, job title, department, primary office location, country, city, manager, and your training activities, results, and records. 

Information we collect

Each time you use the Platforms & services we may automatically collect the following information: 
• A record of the details of your usage, including the date, time, location, frequency and duration. 
• Technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type. 
• Other information about your use of the Platforms & services, including the pages you have viewed, the duration spent on the Platforms & services  and data files you have uploaded to the Platforms & services. This information may be linked to your user profile (where relevant). 

Information provided by other sources

We work closely with third parties (including for example, business partners, subcontractors, and analytics providers), and we may receive information about you from them. Details of third party providers are described in the section below: “Who we share your information with”.

How we process and use personal data

Please note that we process all personal information in accordance with the Agreement.
Where we have collected, received, or generated personal data from or about you, we may process and use this for the purposes as set out below.

Information you or your organization provide

We will use this information to: 
• Carry out our obligations arising from the Agreement, including deliver platform and services to your organization as the Agreement specifies. 
• Contact you for feedback on our platform and services and to help us evaluate and improve these, for example by acting on any information you have provided to us. 
• Notify you about changes to the Platforms and any other services of ours that you use, including informing you about new versions of the Platforms & services and about new features, functionality and service offerings. 
• Deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your organization) involving you and any issues caused by your use of the Platforms & services. 

Information we collect

We will use this information:
• To administer and improve the Platform and other services, including ensuring that content is presented in the most effective manner for you and for your computer or device. 
• To report to your organization relating to the use of the Platforms & services. 
• For internal operations, including troubleshooting, data analysis, testing, research and development, statistical and survey purposes. 
• To allow you to participate in interactive features of the Platforms & services. 
• As part of our efforts to keep the Platforms & services safe and secure. 
• To compile general Platform usage reports (which do not personally identify you). 
• In an aggregated and anonymized form for statistical and benchmarking purposes, including comparisons to other organizations, e.g. within the same industry or geographical location.

Information provided by other sources

We may combine information from other sources with the information you give to us or we collect about you and use this information as specified above.
In relation to the above uses, we shall process your personal data on the legal basis determined by your organization or where it’s necessary for the purposes of our legitimate interests, including:
• to enable us to perform our contractual obligations under the Agreement;
• to improve or optimize our services;
• to maintain the security of our computer systems;
• to understand how the Platform is used and to improve the user experience of the Platform;
• to protect and defend our legal rights;
• for troubleshooting, and
• for data analysis, testing and research and development purposes.

Who we share personal data with

We may also share your personal data with selected third parties in accordance with this policy, including:
• Sub-processors, service providers (for example of IT services), business partners and/or suppliers for the performance of any contract that we enter into with your organization (such as the Agreement), including the following:
• Microsoft who provide cloud hosted infrastructure and services used by us to operate the Platform as a hosted solution.
• Microsoft Inc., Zendesk Inc. who provide product tools and functionality used by us in delivery of the Platform and associated services.
• Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
We require all our third party service providers to take appropriate and stringent security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.
We may also disclose your personal data to other third parties in the following circumstances:
• If we sell or buy any business assets or receive investment into our business, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business or assets;
• If Zensai International ApS or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your data and data about our customers, suppliers and correspondents will be one of the transferred assets;
• We may disclose your personal data to our legal advisers if they need to have access to this information in order to advise us on our legal rights and obligations; and
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or other contracts between us and you or your employer; or to protect the rights, property or safety of us, our customers or others.

No personal data will ever be used or shared by Zensai and/or Partners in respect to marketing.
Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.

International data transfers

We may use service providers that are based outside the European Union and European Economic Area, most likely in the United States. We may transfer your personal data to such services in order to provide our services via the Platform.
We have put in place appropriate measures to ensure that your personal data are treated by such third parties in a way that is consistent with and which respects the EU laws on data protection, including putting in place written contractual agreements to meet EU-approved data protection obligations. If you require further information about these protective measures, please contact us at [email protected].

Security

We maintain relevant technical and organizational measures to ensure an appropriate level of security in respect of all customer and personal data we process. Details about security and encryption and data breach procedures for our platforms and services are available for your organization online in our Trust Center.

Consent and retention period

Since your access to use the platforms & services and your usage is administrated by your organization, the user consents required for the platform to function as intended is granted on behalf of you as a user by your organization.
Details of this administrative consent are specified for your organization online in our Trust Center.
General information for your organization about retention and deletion of data, e.g. on request or following termination of the Agreement is available online in our Trust Center.

Your rights in relation to personal data

As stated above our use and processing of your personal data is governed by the Agreement with your Organization. Even so, you always have certain rights in regards to your personal data, which are listed below.
• Access: You have the right to access information about the personal data we hold about you.
• Right to object to processing: You have the right to object to processing of your personal data.
• Rectification: You have the right to request rectification of inaccurate personal data held about you.
• Erasure: To the extent permitted by applicable data protection laws, you have the right to request erasure of personal data held about you.
• Request to restriction of processing: This enables you to request to restrict the processing of your personal data in certain circumstances.
• Portability: You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies.
• Automated processing: Not to be subject to a decision based solely on automated processing, including profiling (“Automated Decision-Making”).
In case you would like to exercise any of these rights in relation to your use of the platform and services we deliver to your organization, please contact your organization’s platform responsible directly.
Information for your organization about GDPR compliance with regards to their platform users’ personal data are available in our online Help Center.

Cookies & similar technologies

Our Platform uses cookies, which are small text files placed on your device, and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you use the Platforms & services, and it also assists us in our efforts to improve the Platform. Cookies enables us to, among other things, store your preferences and settings; enable you to sign-in; combat fraud, and analyze our platforms and services.
We use cookies specifically for authentication, application insights, and general platform analytics and diagnostics.
You have various tools to control cookies, and similar technologies, including your browser controls to block and delete cookies , e.g. from third-party analytics service providers, and to opt out of data collection through web beacons.
Your browser and other choices may impact your experiences with our services.

Changes to the Privacy Policy

Changes to the platform and services we deliver to your organization are released and communicated as specified in the agreement. In relation to platform and services updates and improvements, or for other reasons, we may update and amend our Privacy Policy from time to time.
Where we make changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

How to contact us

Your organization’s use of our platform and services are typically administrated by certain people in your organization, who will have the responsibility to govern the usage. In most cases the platform responsible will be the point of contact for any questions or issues relating to use of the platform within your organization, including concerns relating to data processed via the platform. Usually it will also be this platform responsible who will be the point of contact between us and your organization, for instance relating to requests for support or professional services.
If your organization or you have questions to this Privacy Policy you are welcome to reach out to our responsible Compliance Officer via email to [email protected] or send your request via regular post services to Zensai International ApS, Mariane Thomsens Gade 4B, 5., 8000 Aarhus, Denmark.
We are committed to resolving any privacy concerns you may have. However, if you feel we have not addressed your specific concern, you have the right to make a complaint at any time to the relevant supervisory authority in your country responsible for data protection issues.