ZISHI Adaptive leverages the potential that exists within advanced technologies and tools enabling clients to recruit, retain, and mentor the best talent. Your privacy and security are critically important to us. We are committed to being transparent about how we collect and use personal data and how we meet our data protection obligations. Please read the following carefully prior to using the website or the service in order to understand how we will safeguard your personal information and how that information may be collected, used, or shared.

We are the Data Controller with respect to the personal data of users of the ZISHI website.

If you have directly accessed the Adaptive service, (for example through the widget on a 3rd party website) then we are the Data Controller for this service.

If you have been referred to the Adaptive service from your organisation then we will process your personal data only on their specific instructions.

If you have consented to us sharing your data with a 3rd party to enable them to send you information on brokerage services, trading performance technology and/or financial education the 3rd party identified in the consent form will be the Data Controller.

HOW WE USE YOUR INFORMATION:

With respect to our website, we may use the information we collect in the following ways:

  • To better understand how visitors interact with the content on our website so that we may optimize that content and its location to provide the best visitor experience.
  • To better understand what technology visitors are using to interact with our website so that we may optimize our website for you.

With respect to the ZISHI Adaptive Personality and Cognitive Survey, we process your personal data to generate your Trader DNA Report. Where you have given your consent we will also process your personal data to provide the identified 3rd party with information regarding your preferences.

Where you have been referred to us by your organisation we will only process your personal information according to their instructions. If you have questions about your personal data, or want to exercise any of your rights regarding your personal data collected for this purpose, please contact the client which referred you to ZISHI Adaptive.

WHAT INFORMATION DO WE COLLECT?

We may collect some or all of the following types of information from and about visitors to our website:

  • Information that is about you but does not personally identify you, including, but not limited to, information about your web browser, language preference, referring site, and the date and time of each visitor request.
  • Information that is about you and can potentially be used to identify you, including, but not limited to, your internet protocol (IP) address.
  • Aggregated statistics about the behaviour of visitors.

When clients refer you to us for a service we only collect your name and email address.

LAWFUL BASIS FOR PROCESSING YOUR DATA:

Contract: Where data is collected for the purpose of fulfilling a contract with yourself or a client, we will use your data on the basis that processing is necessary to fulfil that contract and on the understanding that the client has obtained all necessary consents from you.

Legitimate Interest: Where we have a legitimate interest (which you may object to at any time) to process data, we will use your data on the basis that we have legitimate interest to do so which is not overridden by your rights and freedoms, which may include the following types of processing:

  • help us identify you so we know who we are talking to;
  • help prevent and detect fraud or loss;
  • assess risk, carry out market research, statistical analysis, test systems, improve our services; and
  • train staff and monitor our services. This may mean that we record our conversations or our correspondence with you to make sure we are providing you with a good service and to make sure we keep to our legal and regulatory obligations.
  • To improve service provision.

Legal Obligation: Where we are required to process data in order to comply with our legal obligations, we will use your data on the basis that it is necessary to do so for the purposes of legal compliance, which may include storing your data in order to establish, exercise or defend legal claims within the relevant statutory limitation periods.

Consent: Your consent will be obtained for processing that requires such consent, and in particular where data is transferred outside of EEA.

WHO HAS ACCESS TO YOUR DATA?

We may disclose your personal information to any of our subsidiaries, affiliates or their successors or assigns, contractors, service providers, or other third parties that we use to support our business or that we partner with in order to provide you with additional features or services. Any entity with whom your personal information is disclosed is authorized to use that data solely as needed in order to provide you with services. We do not sell your personal information.

Where you have provided your specific consent we may disclose your information to 3rd parties to enable them to provide you with information on brokerage services, trading performance technology and/or financial education.

We may also disclose your personal information to comply with any applicable law, regulation or government request or to protect our rights or the rights of our customers, users, partners, or others.

In the event that we sell all, or substantially all, of our assets to a third party, your personal data held by us will be transferred as part of the sale and we will endeavour to provide you with notice of such event.

SUB-PROCESSORS:

We use Survey Monkey to process the ZISHI Adaptive Personality and Cognitive Survey. Their privacy policy can be viewed here.

HOW DOES ZISHI ADAPTIVE PROTECT YOUR DATA?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 and in accordance with our instructions.

TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Given the international dimension of ZISHI Adaptive, and in order to optimize the quality of our services, the communication of information mentioned above may involve the transfer of personal data outside the EEA, whose legislation on the protection of personal data is different from that of the European Union.

Where we transfer personal data outside the EEA (except where the concerned country has been officially recognized by the European Commission as ensuring that personal data has an adequate level of protection equivalent to the European standard), we will ensure that the transferred data is protected by suitable Standard Contractual Clauses or other appropriate safeguards referred to in the GDPR.

FOR HOW LONG DOES ZISHI ADAPTIVE KEEP DATA?

We will only retain personal data for as long as necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any contract, legal, accounting, reporting requirements, or to comply with internal policy requirements.

YOUR RIGHTS UNDER THE GDPR:

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information 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.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct, request erasure or object to the processing of your personal information; request that we transfer a copy of your personal information to another party; or if you have any general queries about how we handle your personal data, please email: gdpr@thezishi.com.

If you have any concerns about our use of your personal information, you can make a complaint to us at gdpr@thezishi.com

You can also complain to the Information Commissioners Office if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF