Privacy Policy                              Last Updated: March 2021

This privacy policy (together with our Terms of Use and any other documents referred to in either document) describes how Deep Zen Limited (“DeepZen”, “us”, “our”, and “we”) collects, uses and shares personal information belonging to website users, our customers and end-users who use our services and products either through our website (www.deepzen.io) (the “Site”) or any customer portal (which allows text-uploads and transfers of files from customers to us) which link to this Policy.

Please read this privacy policy carefully to understand our practices toward your Personal Data. By visiting the Site, using our services or sending us information you accept and consent to the practices described in this policy. DeepZen has updated this policy to take account of improved functionality associated with our customer portals (through which text files and other data is transferred to us) but also to take account of evolving data protection law. We adhere to Regulation (EU) 2016/679 (the “EU GDPR”) as it continues to apply to our activities or customers in the EU. We also comply with the retained version of the EU GDPR as it applies from 1 January 2021 in the UK (as amended and updated from time to time) (the “UK GDPR”).

WHAT WE COLLECT

We get information about you in a range of ways.

• Information You Give Us

We may collect your‎ name, postal address, email address, phone number, fax number, username, password, demographic information (such as your gender and occupation) as well as other information you directly give us whether on our Site or otherwise (your “Personal Data”) if, among other things, you:

• register to become a user of our Site;
• send us a message or correspond with us by telephone, in writing or otherwise;
• become a user of our products or services;
• participate in a discussion board on the Site; or
• report a problem to us.

• Information We Get From Others

We may get information about you from other sources such as customers and partners. Some customers have access to a portal which allows them (subject to appropriate terms and conditions) to upload or transfer text files for the purpose of the automated production of audio files. There will be occasion when the source material received by us will contain personal information. We may add this to information we get from this Site and other sites.

• Information Automatically Collected

We may automatically log non personally identifiable information about you and your computer. For example, when visiting our Site, we may log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, access times, pages you viewed, how long you spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs) and other information about your use of and actions on our Site. From time to time, we may release non personally identifiable information in the aggregate, e.g., by publishing a report on trends in the use of the Site or by releasing statistics about the behaviour of visitors on the Site. We may also collect potentially personally identifiable information such as Internet Protocol (IP) addresses for logged-in users and for users leaving comments on discussion board posts on the Site. We disclose any such personally identifiable information subject to the same policies described under “Sharing of Personal Data” below.

Does the Personal Data we collect make us a Data Controller or Data Processor?

We are a data controller for our business decisions, employee data, our operational systems and our AI voice solutions. However, there are occasions and activities where we act under instruction from customers or partners (who determine the content and inputs of text into our system) and they will be the data controller in that use-case (and we will be acting as data processor). The diagram helps explain the difference.

DeepZen’s use of Cookies

We log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both (1) session cookies (which are added automatically to your browser by the server software but not used by our Site and expire once you close your web browser) and (2) persistent or analytical cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site; such cookies may record, among other things, the time of your first visit to the Site, the time of your most recent visit to the Site, the time of your current visit to the Site, which page(s) you visited on the Site, how long you stayed on the Site and how you located the Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. Many browsers are set to accept cookies until you change your settings. However, you can typically remove and reject cookies from our Site with your browser settings, or adjust your browser to tell you when a website tries to put a cookie on your computer. Users based in the European Union can opt out of these third-party cookies. This website is not connected to us and we are not responsible for its content. We only keep cookies for the duration of your visit to our Site, except in the case of cookies which remember you for future visits or where you save your login name as referred to above. If you remove or reject our cookies, it could affect how our Site works for you.

OUR LAWFUL BASES FOR COLLECTING AND USING YOUR PERSONAL DATA

We have listed a wide range of information-types in the previous section. Data protection laws requires DeepZen to have one or more lawful bases (as set out in the EU GDPR and UK GDPR) for processing and holding your Personal Data. The six forms of lawful basis that are available are summarised in the info-graphic below:

DeepZen works with many partners, customers and professionals involved in all aspects of the audio-output industries. This includes many such as authors, marketers, production companies, agencies, game developers, educators, voice artists, content creators, with whom we will have contractual obligation to fulfil– where we need to perform our agreements with each out of contractual necessity.

There are other occasions when DeepZen reserves the right to directly take your freely given, unambiguous and informed consent to our processing of your data. More often when you indirectly use our products or services – most likely when you use the services of a customer of ours who in turn will have recourse to a customer portal with us- you will have consciously consented to the processing of your information as part of that arrangement.

Please note however as a general rule, we do not rely on consent as a legal basis for processing your personal data although we will endeavour to adhere to all relevant “privacy in electronic communications” regulations and obtain your consent before sending third party direct marketing communications to you via email or text message. In any case you will always have the right to withdraw consent to marketing at any time by contacting us.

There will be many other occasions, especially for our out-reach initiatives and programmes where we validly rely on our legitimate interests as a modern business bringing our innovative solution to the market.

Please be assured, when we do use your data for outreach purposes, we will do so responsibly. We will ensure periodically that we continue to have a legitimate interest in doing so (in compliance with EU GDPR and UK GDPR ). This means that through this policy we are happy to commit to continually assessing our legitimate business needs against the needs to maintain and protect individual rights and freedoms. We are happy to make our up to date assessment of our legitimate interests available to you upon request.

In summary, we conduct a 3-stage test to challenge ourselves and confirm our legitimate interests to hold personal data as follows:

• We identify what our legitimate business interests are at any given time – and these will almost always include our core business intention to innovate and modernise in the field of audio production and output using our cutting-edge technology and knowhow. This has wider societal benefits outside and additional to our own objectives as a company.
• We check the necessity of processing a customer, contact or stakeholder’s personal data in order to properly deploy, test, educate the market and improve our products and services. We check that there are no any less intrusive means to deliver Deep Zen’s functionality than through the kinds of contact and outreach we engage in.
• We make sure we weigh the balance of the interests of our business and our technological solution with the interests of the people we contact and whose information we hold. We remain of the view our actions and communications progress is proportionately conducted whilst respecting the rights of individuals as far as possible, as we grow and reach new markets and more customers.

Finally, we ensure that our legitimate interests are prudently counterbalanced against the constant right of individuals to make a data access request to us (such as an objection to processing). Anyone can make such a request to us at any time.

USE OF PERSONAL DATA

We may use your Personal Data as follows:

• to operate, maintain and improve our Site, products, and services;
• to publish and highlight testimonials on our Site from individual people and partners we have worked with
• to respond to comments and questions and provide customer service;
• to send information including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages.
• to communicate about promotions, upcoming events and other news about products and services offered by us and our selected partners;
• to link or combine user information with other Personal Data;
• to protect, investigate and deter against fraudulent, unauthorized, or illegal activity; and
• to provide and deliver products and services which customers request through a customer portal or otherwise.

SHARING OF PERSONAL DATA

Your Personal Data will not normally be disclosed to third parties except for where it is necessary for fulfilment of our obligations to you, or where we are obliged or permitted to do so by law (including, without limitation, through the terms of any customer terms and conditions or other agreement that may be in place ). We may share your Personal Data as follows:

• We may share Personal Data with your consent. For example, you may let us share Personal Data with others for their own marketing uses. Those uses will be subject to their privacy policies.
• We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• We may share Personal Data for legal, protection and safety purposes.
• We may share information to comply with laws including contracts that we have in place with customers and others.
• We may share information to respond to lawful requests and legal processes (including by law enforcement agencies or any regulatory or government authority in response to any request including requests in connection with the investigation of any suspected illegal activities).
• We may share information to protect the rights and property of DeepZen Limited, our agents, customers and others. This includes enforcing our agreements, policies and terms of use.
• We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
• We may share information with those who need it to do work for us.

We will not sell, resell, lease or license your Personal Data to any third parties but we may, if required for the purpose(s) for which your Personal Data was collected and processed, share it with our partners or with our service providers, for the specific scope of their provision of services.

We may also share aggregated and/or anonymized data with others for their own uses.

USE OF YOUR PERSONAL DATA OUTSIDE THE UK & EU

In order to provide you with requested products and services we may need to transfer your Personal Data to service providers based in countries outside the UK and European Economic Area (the “EEA”) or to our overseas partners. This does not diminish your rights. DeepZen Limited will take all reasonable steps necessary to ensure that any Personal Data transferred outside the UK and EEA will be treated securely and in accordance with this privacy policy and with UK GDPR or EU GDPR as the case may be.

INFORMATION CHOICES AND CHANGES

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

You may send requests about Personal Data to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others and update your Personal Data.

SECURITY

We have policies and technical measures in place designed to safeguard and protect your Personal Data against unauthorised access, accidental loss, improper use and disclosure. However, you should remember that electronic communications and the internet are not completely secure. While we will do our best to protect your Personal Data, the transmission of your data to us is done so at your own risk.

LINKS TO EXTERNAL SITES

This Site may contain links to external sites not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy and the terms of use of every external site you visit.

We have no control over and assume no responsibility for the content, privacy policies, terms of use or practices of any third party sites, products or services.

YOUR RIGHTS

For the limited amounts of personal data we hold, you have enshrined rights under the EU GDPR and UK GDPR:

• The right to be informed about our use of your data. This is met by this Policy.
• The right to access information we hold about you and to obtain information about how we process it (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Please note that we may ask you to specify what you wish to see in order to focus our search, and we may have to verify your identity/authority.
• In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• In some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party;
• The right to request that we rectify your information if it’s inaccurate or incomplete though we may need to verify the accuracy of the new data you provide to us.
• In some circumstances, the right to request that we erase your information where there is no good reason for us continuing to process it. We may continue to retain your information if we’re entitled or required to retain it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• The right to object to, and to request that we restrict, our processing of your information in some circumstances for example where we are relying on our legitimate interests or using it for direct marketing. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing it and/or to refuse your request.

CONTACT INFORMATION

We welcome your comments or questions about this privacy policy. You may contact us at our primary place of business (below), phone number or e-mail address.

Attn: CEO

DeepZen Ltd.

151 Wardour Street

Soho

London W1F 8WE

United Kingdom

Telephone: +44 20 3948 1833

Email: hello@deepzen.io

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy. If we make any changes, we will change the Last Updated date above.