Privacy Policy

1. Introduction

This Privacy Policy explains how Pobece Zuhuzi ("we", "us", "our"), operating the website pobece-zuhuzi.info, collects, uses, stores, and protects personal data in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), as retained in Irish law through the Data Protection Act 2018, and the EU ePrivacy Directive as implemented in Ireland by the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

We are committed to handling personal data responsibly and transparently. This document is intended to inform you clearly about your rights and our obligations. If anything is unclear, you are welcome to contact us using the details in Section 13.

2. Data Controller

The data controller for this website is:

As data controller, we determine the purposes and means of processing your personal data. We do not currently have a designated Data Protection Officer, as our processing activities do not meet the threshold requiring one under Article 37 GDPR. However, data protection enquiries may be directed to the contact details above.

3. What We Collect

We collect personal data only where necessary and proportionate to the purposes described in this policy. The categories of data we may collect include:

Contact form submissions: When you use the contact form on this website, we collect your name, email address, telephone number, the subject of your enquiry, and the content of your message.

Newsletter subscriptions: If you subscribe to receive updates from us, we collect your email address.

Technical data: When you visit this website, our hosting provider may automatically collect technical information including your IP address, browser type, operating system, referring URL, and pages visited. This information is collected for security and operational purposes.

Cookie data: We use cookies and similar technologies as described in our Cookie Policy and in Section 8 of this document.

We do not collect sensitive personal data (as defined in Article 9 GDPR), financial account information, or data from children under the age of 16.

4. How We Use Your Data

Personal data collected through this website is used for the following purposes:

Responding to enquiries: Data submitted via the contact form is used to read and respond to your message. We do not use this data for any other purpose without your consent.

Newsletter delivery: Email addresses collected for newsletter purposes are used solely to send editorial updates from this publication. You may withdraw consent at any time.

Website operation and security: Technical data is used to maintain the security, integrity, and performance of this website. This includes identifying and responding to security threats or technical errors.

Legal compliance: We may use or retain data where required by applicable Irish or EU law.

We do not use personal data for automated decision-making or profiling as defined in Article 22 GDPR. We do not use personal data for direct marketing beyond the newsletter service to which you have explicitly subscribed.

5. Legal Basis for Processing

Under Article 6 GDPR, all processing of personal data requires a lawful basis. The bases we rely on are as follows:

Consent (Article 6(1)(a)): Where you have freely given, specific, and informed consent. This applies to newsletter subscriptions and to the use of non-essential cookies.

Legitimate interests (Article 6(1)(f)): For processing necessary for our legitimate interests, including operating and securing this website, where those interests are not overridden by your rights and freedoms. We have conducted a legitimate interests assessment for each such use.

Legal obligation (Article 6(1)(c)): Where processing is required by applicable law.

Where we rely on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law.

Contact form data is retained for a period sufficient to address your enquiry and for a reasonable period thereafter in case of follow-up correspondence, after which it is securely deleted.

Newsletter subscriber email addresses are retained until you unsubscribe or request deletion. Technical and log data retained by our hosting provider is subject to their own retention policies, which are typically no longer than 90 days.

We review data holdings periodically and delete data that is no longer required.

7. Sharing of Personal Data

We do not sell, rent, or trade personal data. We do not share personal data with third parties for their marketing purposes.

We may share data with service providers who assist in operating this website, such as our hosting provider. Such providers act as data processors under Article 28 GDPR and are contractually required to process data only on our instructions and in accordance with this policy.

We may disclose personal data where required by law, by court order, or by a competent regulatory authority in Ireland or the European Union.

If data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission under Article 46 GDPR.

8. Cookies

This website uses cookies and similar technologies. Cookies are small text files stored on your device when you visit a website. We use cookies for the purposes of website functionality and, where you have consented, for analytics.

You can manage your cookie preferences using the cookie consent tool available on this website. Detailed information about the specific cookies we use is provided in our Cookie Policy.

Where cookies require your consent under the ePrivacy Regulations, we obtain that consent before setting them. Strictly necessary cookies do not require consent and are set automatically to enable the website to function.

9. Your Rights

Under GDPR, you have the following rights in relation to your personal data:

Right of access (Article 15): You may request a copy of the personal data we hold about you.

Right to rectification (Article 16): You may request correction of inaccurate data.

Right to erasure (Article 17): You may request deletion of your data in certain circumstances.

Right to restriction (Article 18): You may request that we restrict processing of your data in certain circumstances.

Right to data portability (Article 20): Where processing is based on consent or contract and carried out by automated means, you may request your data in a portable format.

Right to object (Article 21): You may object to processing based on legitimate interests.

Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at [email protected]. We will respond within one month as required by Article 12 GDPR. You also have the right to lodge a complaint with the Data Protection Commission (DPC) of Ireland at www.dataprotection.ie.

10. Security

We take appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or alteration, in accordance with Article 32 GDPR. These measures include the use of secure hosting, access controls, and regular review of our data handling practices.

No method of electronic transmission or storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security. If you have concerns about a specific security matter, please contact us directly.

11. Children

This website is not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16. If you believe we have inadvertently collected data from a child, please contact us and we will take steps to delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The date at the top of this document indicates when it was last revised. We encourage you to review this policy periodically. Continued use of this website after changes are posted constitutes acceptance of the revised policy, to the extent permitted by law.

13. Contact

For any questions or concerns about this Privacy Policy or our data handling practices, please contact us: