Privacy Policy

Privacy Data Protection Policy

The General Data Protection Regulation
                             The General Data Protection Regulation (GDPR) is a standout amongst the most noteworthy bits of enactment influencing the way that Zenjex does its data preparing exercises. Huge fines are relevant if a break is esteemed to have happened under the GDPR, which is intended to secure the individual information of nationals of the European Union. It is Zenj Exchange’s strategy to guarantee that our consistence with the GDPR and other important enactment is clear and verifiable consistently.
GDPR Fundamental Concepts
                             The most important concepts from GDPR regulation that are consistent within our organization and apply properly for this policy are the following:
Personal data is defined as:
                             Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
‘Processing’ means:
                             Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
‘Controller’ means:
                             The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
                             As per GDPR regulation, 2016 version, there are 7 principles involving personal data and how companies should treat these aspects.These are as follows, as per Chapter II, Article 5.1
1. Personal data shall be
             a. processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
           b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);
             c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
             d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
             e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
             f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
2. The Controller :
                The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).Zenj Exchange complies with these principles by using business workflows based on technology that use metadata in order to search, discover, classify, label, protect and apply actions at all levels of personal data. Also, Operational Security Procedures defined support and provide the specific guidelines for all teams involved including Finance, TMU, BDU, PMU and RDU.
                   Any staff member of Zenj Exchange who is involved in the collection, storage or processing of personal data has responsibilities under the legislation. Any staff member involved in the processing/storing of personal data should make sure:
• to obtain and process personal data fairly.
• to keep such data only for explicit and lawful purposes.
• to disclose such data only in ways compatible with these purposes
• to keep such data safe and secure.
• to keep such data accurate, complete and up-to-date.
• to ensure that such data is adequate, relevant and not excessive.
• to retain such data for no longer than is necessary for the explicit purpose.
                   The data subject also has rights under the GDPR. These consist of:
1 The right to be informed
2 The right of access
3 The right to rectification
4 The right to erasure
5 The right to restrict processing
6 The right to data portability
7 The right to object
8 Rights in relation to automated decision making and profiling. Each of these rights must be supported by appropriate procedures within Zenj Exchange that allow the required action to be taken within the timescales stated in the GDPR.
These timescales are shown below:
Data Subject Request Deadline
The right to be informed when data is collected (if supplied by data subject) or within one month (if not supplied by data subject)
The right of access One month
The right to rectification One month
The right to erasure without undue delay
The right to data portability One month
The right to object On receipt of objection
Rights in relation to automated
Decision making and profiling. Not specified
                             Unless it is necessary for a reason allowable in the GDPR, explicit consent must be obtained from a data subject to collect and process their data. Transparent information about our usage of their personal data must be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained, such as the right to withdraw consent. This information must be provided in an accessible form, written in clear language and free of charge. If the personal data are not obtained directly from the data subject then this information must be provided within a reasonable period after the data are obtained and definitely within one month.
                            Zenj Exchange has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues, including the completion of one or more data protection impact assessments. The data protection impact assessment will include:
• Consideration of how personal data will be processed and for what purposes
• Assessment of whether the proposed processing of personal data is both necessary and proportionate to the purpose(s)
• Assessment of the risks to individuals in processing the personal data
• What controls are necessary to address the identified risks and demonstrate compliance with legislation Use of techniques such as data minimization and pseudonymisation should be considered where applicable and appropriate.
                          Transfers of personal data outside the European Union must be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgement as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time. Intra-group international data transfers must be subject to legally binding agreements referred to as Binding Corporate Rules (BCR) which provide enforceable rights for data subjects.
                           A defined role of Data Protection Officer (DPO) is required under the GDPR if an organization is a public authority, if it performs large scale monitoring or if it processes particularly sensitive types of data on a large scale. The DPO is required to have an appropriate level of knowledge and can either be an in-house resource or outsourced to an appropriate service provider. Based on these criteria, Zenj Exchange, doesn’t require a Data Protection Officer to be appointed.
                            It is Zenj Exchange’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant Data Protection Authority (DPA) will be informed within 72 hours. This will be managed in accordance with our Information Security Incident Response Procedure which sets out the overall process of handling information security incidents. Under the GDPR the relevant DPA has the authority to impose a range of fines, for infringements of the regulations.
The following actions are undertaken to ensure that Zenj Exchange complies at all times with the accountability principle of the GDPR:
• The legal basis for processing personal data is clear and unambiguous
• All staff involved in handling personal data understand their responsibilities for
• following good data protection practice.
• Training in data protection has been provided to all staff.
• Rules regarding consent are followed.
• Routes are available to data subjects wishing to exercise their rights regarding personal.