ZISHI Elite leverages the potential that exists within advanced technologies and tools enabling you to assess the impact of trading on stress and energy, health and well-being and the subsequent impact of that stress and low energy on trading decisions and performance. The process involves measuring your physiological states using Heart Rate Variability (HRV) data and basic lifestyle factors, such as sleep, physical activity, mood etc.

As part of this process, we will collect your personal data, which will be analysed and used to help determine correlation between the above variables and your performance, thereby highlighting your optimal performance zones. It also aims to help support you in the area of wellness.

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 Website and business contacts.

We are the Data Controller in respect to the personal data of data subjects referred to us by clients in order to participate in the ZISHI Elite service.

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 Elite Service, we process personal data only in order to provide the service to you: 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 our Data Protection Officer at GDPR@thezishi.com

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 behavior of visitors.
ZISHI Elite collects a range of information about you:
  • Wellbeing Data: This includes heart rate variability and other data collected by the biometric devices, and additional information manually input by the Participant themselves, such as sleep quality, quantity and mood. Wellbeing Data will relate to a specific Participant; and
  • Performance Data: This includes timespan, number of trades, profits and loss. Performance Data will relate to a specific Participant.
  • Contact Data: email address, mnemonic, unique identifier, first name and last name.

ZISHI Elite may collect this information in a variety of ways. For example, data will be  collected upon registration, through interviews, questionnaire or other forms of assessment. Also by using Polar H10 or CorSense device (or a similar device) to capture HR & HRV. Data will be stored in a range of different places, including on your Polar H10 or CorSense device (or similar device), ZISHI Elite App, management systems and on other IT systems (including email).

Lawful basis for processing your data:

Contract: Where Data is collected for the purpose of fulfilling a contract with you, we will use your Data on the basis that processing is necessary to fulfil that contract.

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.

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 we process your health related data or data is transferred outside of the UK and/or EEA.

Who has access to your data?

Your information may be shared internally for administration purposes. This includes members of the ZISHI Elite team, Application developers, IT staff if access to the data is necessary for the performance of their roles.

Your information will also be shared with third parties like Bangor University Professors to conduct analysis to determine correlation between variables and Trader’s performance.

Under no circumstance will your data be sold or shared with any parties who are external to the company or project other than those listed above.

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 endeavor to provide you with notice of such event.

Sub-processors:

We partner with Bangor University to conduct analysis to determine correlation between variables and Trader’s performance. We have a data sharing agreement in place to ensure that your data is protected to the same standard as our internal policies and controls to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by employees in the proper performance of their duties.

How does ZISHI Elite 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.

Where we have need to share your data with third party organisations, we ensure it is transferred via secure transmission methods.

Transfers of personal data outside the European Economic Area (EEA)

Given the international dimension of ZISHI Elite, 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 UK and/or EEA, whose legislation on the protection of personal data is different from that of the UK and/or European Union.

Where we transfer personal data outside the UK and/or 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 DPA2018 and GDPR.

For how long does ZISHI Elite 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 DPA2018:

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.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance of data protection laws. Our DPO can be contacted at gdpr@thezishi.com.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF