Privacy Policy

Privacy Policy

Please note that any words, which are capitalised, have the same meaning as in the Terms of Use for use of the Sites and the Service.

A. Introduction
We are Zusheti trade name for Lemak Solutions Limited, Company No 07801336 registered in England with our registered office at 5 Jupiter House Calleva Park, Aldermaston, Reading, RG7 8NN, England (and we refer to ourselves as “Zusheti”, “we” or “us” or “our” in this document).
We are committed to protecting your privacy. We ask that you please read the following carefully to understand our views and practices regarding your personal data and how we, as data controller of your personal data, will treat it.
We will only use the information that we collect about you lawfully (in accordance with the Data Protection Act 1998 and other applicable data protection laws in the UK).

B. The Information We Collect
Big Data
You may have heard about Big Data. That means that we learn information about you from what you provide to us at different times and in different ways and possibly also from various other sources. This information may be put together by us to give us a more detailed ‘picture’ of you. We do this for all the reasons set out in this privacy policy under the section called “How We Use the Information We Collect”. But we will only ever give this “picture” of you to anyone else for the reasons set out the section of this privacy policy called “Data Sharing”– which means virtually never unless it is anonymised so that third party cannot work out who you are. Again, we do this for all the reasons in this privacy policy
Data we collect from you directly
When you register to use the Sites we will ask for the following information: your email address and password. We may also ask you to provide your age range, your phone number, and possibly certain other personal details such as gender or where you heard about us.
In addition, you will be able to register for the third-party website of a Shops/stores via Zusheti. If you insert any information in such third party registration form we may use such information in accordance with this Privacy Policy. However, if such third party registration form includes payment information, this will not be retained and we shall not make any use of such information except to submit such information to the applicable third party together with the entire registration form.
We will also ask you to provide data as you use the Sites so that we can provide the certain aspects of the Services. For example:
•   If you place an order from one of the Shops/Stores, we will ask you for your login details for that Shops/Stores (or you can register for that Shops/Stores via our Website). In addition, from time to time we run surveys of our users so we can learn more about consumer behaviour in general and our users in particular.  You might be invited to participate. Such participation is always voluntary and it will always be clear from the invitation that this is a voluntary survey, and no information is required in order to use our Website. If you do participate, any data provided will be used in accordance with this Privacy Policy.
Data we collect from your activity on the Sites
As you use the Sites and personalise your account, we collect data about your activity on the Sites. This includes things like:
•    Information on what you buy and how you use the Sites, such as:
•    Your favourites;
•    Your sorting preferences;
•    Your product swaps and store switches;
•    Other details about your shops and how you have used the Sites;
•    For each page viewed on a third-party Shops/Stores website via     the Sites, we collect information on the page visited (page URL and title) and information as to how you used that page, although except for that, except as it may be requested from you as part of the Services, we do not collect any personal data about you from a third-party Shops/Stores website and/or from your activity on it while you are using the Services;
• Information about your use of various Sites services;
• Your communications with Zusheti;
• Information about your current location (for users of any Zusheti App). You may opt out of having this data collected at any time by managing your smartphone location services settings;
• Other Information related to your use of the Services;
• Other information related to your activity, such as which website referred you to us;
Data we collect from other sources
We may receive information about you from third-party sources, such as data aggregators and from third parties to whom you have given permission to share your information or from whom you have given us permission to request your information. For instance, by registering for the Sites using Facebook or another social network, you grant permission to that network to share your details. Depending on the network rules and your settings on it, this may include data such as your date of birth, your marital status, the number of people in your household and other information.
Sensitive Personal Data
Sensitive personal data is defined by the Data Protection Act and includes details such as information related to your health, sexual orientation, religion, race or ethnic origin. For the most part, we will not need any Sensitive Personal Data in order to provide our services and we will not request it. However, we may be able to assume sensitive personal data about you from the information you provide. By letting us have any sensitive personal data, you expressly consent to us using and telling others about any of your sensitive personal data so we can provide you with the goods or services requested by you and engage in commercial activities in the way set out in this Privacy Policy.

C. How We Use the Information We Collect
We use the personal data we collect to provide the Services, to customise and improve your Zusheti experience, to make your experience as enjoyable and efficient as possible and for commercial purposes.
Use of Information to Provide the Services
Certain information is required in order for the Services, or certain features of the Services, to operate.
Here are some specific examples of information used to provide the Services.
•    Your email address and password allow us to recognise you when you return so that we can provide you with a faster service and a personal user account.
•    Your postcode allows us to identify which Shops/Stores deliver to your area and what products are available at those Shops/Stores. Products in particular Shops/Stores do sometimes vary by locality.
•    We use your IP address to prevent any spam, fraud or abuse of our site.
•    To import your favourites from any given Shops/Stores and to update these favourites lists when you visit Zusheti
•    To facilitate your registration to a Shops/Stores, we may provide you with the ability to register for a relevant third party website of a Shops/Stores through the Sites. If so, we may pre-populate certain fields in the registration form for that third party website for you. If we do so, it will be for fields for which we already hold your information, such as your name and email address. You always have the opportunity to delete any fields that we pre-populate.
Use of Information to Customise and Improve the Zusheti experience
We want your shopping experience on Zusheti to be as enjoyable as possible. We will collect the data about your shopping activities and preferences to customise your account (in addition to how you customise it yourself) and to enable us to provide an efficient and user-friendly service. We will also use it to improve the quality of the site.
Here are some specific examples of how we use your data:
• We keep details of your favourites from any of the Shops/Stores (if you have chosen to compare them to your Zusheti account), details of items you have liked. This will allow you to shop more efficiently for future visits.
• Paying attention to how you use the Sites help us to develop improvements to the Sites and the Services.
• If you have been referred to us by a third-party website, we may keep a record of the website that referred you so that we may work out which websites refer more or fewer users to our Sites. We may also have referral arrangements with certain third-party websites and referrers and we may use this data to fulfil obligations that we may have to these third-party websites or referrers.
• We collect and track individual and aggregate information about shopping habits, products and service preferences and selections which users have made and the like. We use this information for the personalisation or general improvement of the Services, but also for the purpose of business research. You can see more about the aggregate information below.
• We collect and track individual and aggregate connection information such as browser type and version, operating system and platform; other software and hardware information and the like. We use this information to understand how and when our users access our services, and so we can further develop our Sites and Services to suit.
Use of Information for Commercial Purposes
Zusheti does not charge non-commercial users for use of the Sites. When you use a service like Gmail, you ‘pay’ for the service by allowing Google to scan your emails and use the information they find to target ads at you. When you use the MSM comparison service, you ‘pay’ for the service by allowing us to use the data we collect about you and about your use of Sites, which we then anonymise, aggregate and sell. In terms of data which is personal to you however, we earn revenues from this (which allows us to keep the Sites online and totally free to our non-commercial users) through industry standard sources and methods including advertising sales which may be targeted to you (including online behavioural advertising, including and personalised retargeting advertising,) and through the sale of business intelligence data (which is anonymised).
Here is how your information is used for this:
•    We use information about your activity on our site, including information about your current location when using the App, in order to present you with targeted advertising—that is, product information, offers and promotions that we think may be interesting to you and that you might like. Without targeting, you will still see advertisements; they are just less likely to be relevant.
•    We share information with certain carefully selected third party partners so that they can:
•    Present you with advertisements and promotional offers that are relevant to you and your interests on both Zusheti and other sites based on your activity on Zusheti or, alternatively;
•    To present you with advertisements on Zusheti based on your activity on other websites. For example, you may see ads for products you viewed on another website while browsing Zusheti.
For more information on data sharing, please see the “Data Sharing” section.
•    We collect and may display or use for the purposes of marketing and advertise the Sites, Services or ourselves, any testimonials you provide us with about the Sites, the Services or ourselves – and we may append to the testimonial your first name (but not your surname) and general geographic location (e.g. City or locale).
•    We collect data on your  (and other users’) activity in respect of products and how users shop online in order to develop business intelligence insights on consumer behaviour in general, in respect of a particular brand or product and other areas. This data (which is anonymised and is based on a statistical analysis of the activity of thousands of users) is sold or provided to Zusheti customers, which include journalists, brands, retailers, researchers and others.  Examples of data we might look at are: which products you seem to prefer; which products you have liked: which Shops/Stores you view or shop the most.
For more information, see the section on Aggregate Information, below.
Use of Your Email Address
We use your email address to communicate with you. Some of these are service emails and are so we can communicate with you about Sites updates or your activity on the Sites. For instance, we may send you service emails:
• After registration for the Services, notifying you of your registration details;
• To send you information which you have asked for; and
• To contact you about the status of ratings or reviews you have submitted using our Services.
In addition, from time to time we may email you marketing emails with Sites news and updates or details of a further price reduction or promotions. These may be marketing for the Sites itself or on behalf of third parties. We may also contact you for market research purposes, either for commercial purposes or so we can get feedback about the Sites.
Your acceptance of the Zusheti Terms of Use means that you are giving us consent to send you these emails. However, you can easily opt out of receiving marketing emails by clicking “unsubscribe” in the relevant email or by updating your email preferences in the “My Account” section of the Sites at any time. Even if you opt out, we will still send you service emails about the Sites itself, your account and your activities on the Sites.
Aggregate Information
Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed and from which it is not possible to work out individual customer identities. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but all such information will be anonymised and no identifying information will be included in the resulting data.
Aggregate data helps us to understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. We use and disclose anonymised aggregate information to provide other products and services, as well for the purposes of evaluating and improving our existing products and services. We also sell such aggregate information, both via our business insights website and through other channels.

D. Security Measures
All of the information we collect about you is stored on our secure servers and will be held securely in accordance with our internal security policy and the law. For example, we use secure encryption to hold passwords (e.g. the password allocated as part of the registration process – which may later be changed) or your login details for a Shops/stores (if you authorise us to save this information).
We may send your information internationally including to countries outside the European Economic Area. While we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, some places outside of the EEA may not have adequate data protection laws at all or may offer differing levels of protection of personal information which are not as high as in the UK. By submitting your data to us, you acknowledge that provided we have used your data in the ways set out in this Privacy Policy, we cannot be held responsible for any use of your data by third parties who receive and process your data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

E. Technology
Zusheti and its partners and service providers use cookies to provide the Services, to customise and improve your Zusheti experience and for commercial purposes. You can find more information on the cookies used by Zusheti, our partners, service providers and other third parties as well as how to manage your cookie choices in our Cookie Policy.


F. Data Sharing
There are a number of instances in which Zusheti may share your personal information. This may be in order to allow us to operate the site, for corporate or statutory purposes or as part of a partnership with a third party. A list of our third-party partnerships appears below. All recipients of your personal data are required to treat it in accordance with the Data Protection Act 1998 and other applicable data protection laws in the UK and this Privacy Policy.
We may make other organisations’ services available, through our sites, although we are not necessarily operating these organisations’ sites. We process any information that we collect when you access a service provided by another organisation under this privacy policy. The information these other organisations collect is governed by their own privacy policies.   A list of any such services and organisations and links to their privacy policies appear below, under Third Party Partnerships.
Your acceptance of the Zusheti Terms of Use means that you are giving us consent to share your personal information with our carefully selected third party partners, including for marketing purposes. However, you can easily opt out of this sharing of your personal information by updating your preferences in the “My Account” section of the Sites at any time. Even if you opt out, we will still share your personal information as needed to operate the Sites or as is needed for corporate or statutory purposes.
Operating Purposes
• We may share your personal information with any member of our group of companies, which means any subsidiaries of Zusheti Limited, or its ultimate holding company and its subsidiaries.
• At times we work with other companies who help us to provide the Services to you or provide other support services pertaining to the operation of the Sites. These companies receive only the personal information required in order to provide services and are not allowed to use that information for anything aside from providing the services.
• We reserve the right to investigate suspected violations of the Terms of Use of the Sites or illegal, fraudulent or inappropriate behaviour on the Sites; and to engage in activities needed to protect the rights, property, or safety of ourselves, of our users, or of others. To that end, and to the extent necessary to achieve the foregoing, we may exchange information with other companies and organisations, including but not limited to Shops/Stores, our affiliates and partners and law enforcement agencies.
Corporate and Statutory Purposes
• We may transfer our databases containing your personal information if we sell our business or part of it and engage in another similar corporate transaction.
• We will share personal information where we are required to share your personal data in order to comply with any legal obligation.
Third Party Partnerships
We may share your personal information with other third parties with whom we have a partnership.

Managing Your Online Choices    
In addition, to the individual link listed below for each partner, many online advertisers (including a number of our partners) are members of industry initiatives which work to improve consumer understanding and awareness about online behavioural advertising as well as to establish codes of good practice for their members.  You can visit the initiative websites for more information about online behavioural advertising and manage your cookie choices for their member companies.

Your Online Choices: http://www.youronlinechoices.com/uk/

Network Advertising Initiative: http://www.networkadvertising.org/choices/

Digital Advertising Alliance :http://www.aboutads.info/consumers/

 Oracle    Zusheti engages in online behavioural advertising audience creation in partnership with Oracle

What information we give them:  your hashed  (encrypted) email address and information regarding your activity on our Website

What they do:  Oracle is a data aggregator that creates “audience segments” used in online behavioural advertising. These audiences are pools of web users who have been grouped together based upon previous web browsing activity and are then served advertising which matches their shared interests and preferences.  Oracle endeavours to anonymise the data used to create online audiences so as to help ensure that individuals cannot third-party. These anonymous audiences are then made available to marketers for use in online behavioural advertising campaigns and to measure the effectiveness of their online advertising.

In addition, Oracle uses anonymised aggregate information as a basis for market research both to improve its own services and as a service to third parties.

Based on your activity on Zusheti and on other websites with whom they have partnerships, Oracle will add you to audience segments, which are used by marketers to serve you with online advertisements, and promotional offers that are relevant to you and your interests on different sites on the Internet or on Zusheti.

You can read Oracle’s privacy policy at: https://www.oracle.com/legal/privacy/privacy-policy.html
https://www.oracle.com/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html

Trendstream    Zusheti engages in research into Internet activity in partnership with Trendstream Limited.

What information we give them:  if you are an existing member of a Trendstream consumer panel, information regarding your activity on our Website.  If you are not an existing member of a Trendstream consumer panel, then the fact that you are not a member is the only information that will be provided.

What they do:  Trendstream is a research company which studies how and why people use the internet and how they feel about various brands, products, services and marketing campaigns.  As part of its research, it creates “consumer panels” which it surveys and tracks. The company uses cookies to invite consumers to participate in surveys, to evaluate the accuracy of targeted advertising and for data collection and modelling.

You can read the Trendstream Survey privacy policy and learn how to manage your preferences for this service at:http://legal.trendstream.net/survey-privacy-policy

NeuStar     
Zusheti engages in online behavioural advertising audience creation in partnership with Neustar. Neustar collects data on behalf of P&G (Proctor & Gamble).
What information we give them:  information regarding your activity on our Website
What they do:  Neustar creates “audience segments” used in online behavioural advertising. The company uses cookies to discover general information about the pages on our sites that you visit, browser information, Internet network data and other non-personal information.  It also collects and processes IP addresses in order to infer other information, such as geolocation. Neustar uses the data collected to place your device in certain audience segments (e.g. food preference segments). This cookie is then recognised when you visit Zusheti and/or other third-party sites, and enables targeted or personalised advertising to be served to you according to the segments your device is in.
Based on your activity on Zusheti and on other websites with whom they have partnerships, Neustar will add you to audience segments, which are used by P&G to serve you with online advertisements, and promotional offers that are relevant to you and your interests on different sites on the Internet or on Zusheti.
You can read the Neustar privacy policy and manage your preferences for this service at:https://www.neustar.biz/privacy
Targeted Advertising / Media Platforms    What they do:  Zusheti and our media partners work with a number of companies offering technology platforms that are used to buy, sell, and deliver online advertising, as well as for the collection, processing and use of data used as a basis for targeted and content-based media campaigns.  These platforms may themselves buy, sell, or deliver ads, or they may solely provide technology or services (e.g. data collection and audience building) that their clients use for those purposes.

These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other third-party websites in order to provide advertisements about goods and services of interest to you. In addition to information about your interaction with
Zusheti or other third-party websites, information collected may include your IP address, Internet network data, browser type and other non-personal information.  The information collected can also be used to infer things about you, such as your demographics (age, gender etc.)

A list of our most commonly used platforms appears below, together with a link to each platform’s website where you can learn more about the platform.

AppNexus
https://www.appnexus.com/en/company/platform-privacy-policy
http://www.appnexus.com/en/company/cookie-policy
Carambola
http://www.carambola.com/privacyPolicy/index.html
Carat Leeds
http://leeds.carat.co.uk/privacy-policy/

Criteo
http://www.criteo.com/privacy/full-privacy-text/
Eyeota
https://www.eyeota.com/privacy-policy/
FusePump

Google DoubleClick AdX/Admeld Service
Google Doubleclick Bid Manager
https://www.google.com/policies/privacy/

Mediacom Programmatic Buying Unit
https://www.groupm.com/us-privacy-policy.

Mindshare World
http://www.mindshareworld.com/about/privacy-policy
Sociomantic
https://www.sociomantic.com/privacy/en/
Tamoco
https://www.tamoco.com/privacy/
Xaxis
https://www.xaxis.com/static/view/privacy-policy-en


G. Obtaining Your Personal Information
You can request a copy of the personal information that we hold about you. Please note that we will need to see proof of identity before processing your request and that there may be an administrative fee (not exceeding the maximum permitted by law) for this. If you find any inaccuracies we will delete or correct them promptly.
Please direct your inquiries to:
Zusheti Inquiries: Lemak Solutions Limited, 5 Jupiter House Calleva Park, Aldermaston, Reading, RG7 8NN, England

H. This Privacy Policy
Please note that this Privacy Policy forms part of the Terms of Use for use of the Sites, Browser Extension and the Services and forms part of the Agreement between you and us. The terms defined in these Terms of Use are used in the same way in this Privacy Policy. Updates to this Privacy Policy are dealt with in the same way as in these Terms of Use.

I. Questions or Comments?
If you have any further questions about our Privacy Policy, please refer to our Terms of Use or contact our Customer Support via support@Zusheti.com. (We’re located at 5 Jupiter House Calleva Park, Aldermaston, Reading, RG7 8NN, England.)

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