Zhoosh Benefits Ltd Privacy Policy



Zhoosh Benefits Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

1.              Important information and who we are

1.1           Purpose of this privacy policy. This privacy policy aims to give you information on how Zhoosh Benefits Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our services or register with our employee portal.

1.2           This policy explains when and why we collect personal information about our clients and its employees, how we use it, how we keep it secure and your rights in relation to it.

1.3           It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.4           Contact details If you have any questions about this privacy policy or our privacy practices, please contact Simon Clews – Director [FR1] [SC2] [SC3] [SC4] in the following ways:

(a)        Email: [email protected]

(b)        Post: Simon Clews, Zhoosh Benefits, 5A Parkway, St. Albans, AL3 6PA; or

(c)         Telephone: 01727 514443

1.5           You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.6           Changes to the privacy policy and your duty to inform us of changes We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.7           Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.              The data we collect about you

2.1           Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a)        Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

(b)        Contact Data includes billing address, delivery address, email address and telephone numbers.

(c)         Financial Data includes bank account and payment card details.

(d)        Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

(e)        Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

(f)          Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(g)        Usage Data includes information about how you use our website, products and services.

(h)        Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.2           We may also collect Special Categories of Personal Data including information revealing racial or ethnic origin, religious or similar beliefs, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

2.3           If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Categories of Personal Data.

2.4           We may collect any information about criminal convictions and offences which is necessary for our Partners for the arrangement of certain types of insurance that may involve disclosure by you to us of information relating to historic or current criminal convictions or offences.

2.5           If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.              How is your personal data collected?

3.1           We use different methods to collect data from and about you including through:

(a)        Direct interactions. You may give us your Identity, Contact, Financial Data and Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us. Some of this information may also be received from your employer.

(b)        Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

(c)         Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including:

(i)          Technical Data from analytics providers such as Google based outside the UK; advertising networks; and search information providers;

(ii)         Identity and Contact Data from data brokers or aggregators and from publicly available sources.

4.              How we use your personal data

4.1           We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(a)        Where we need to process your data to perform the contract we are about to enter into or have entered into with you or your employer;

(b)        Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us;

(c)         Where we need to comply with a legal or regulatory obligation that we are subject to (Lawful Basis).

4.2           Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.3           Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so.


Type of employee information held by Zhoosh


Legal basis of processing

Name, date of birth, gender, date of joining and leaving service

Required information to become a scheme member

Performing our contractual duties in making sure that the employees are covered under the right benefits chosen by the customer

Annual salary, occupation, details of sickness absence over 3 months and work related overseas travel

Required information to obtain and maintain customer insurance policies protecting their employees

Performing our contractual duties in making sure that the employees are accurately covered

Monthly salary, pension contributions, National Insurance number and nationality

Required information to become a member and to enable Zhoosh to process monthly pension contributions

Performing our contractual duties in making sure that the employees are correctly set up with a pension policy and data held is compliant with Money Laundering Regulations

Payroll Number, Address and email address

Required information to become a member and enabling the client to use Payroll number for any reports that we provide

Performing our contractual duties in making sure that the employees are correctly set up with a pension policy and data held is compliant with Money Laundering Regulations[FR5] [SC6] 

4.4           Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.5           Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

4.6           Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.7           Opting out You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services we are providing to you.

4.8           Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.zhooshbenefits.co.uk/cookies

4.9           Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.              Disclosures of your personal data

5.1           Your personal data may be shared with our Partners for the activities we have described above. We permit them to use it so that they can deliver the relevant service to you, and if they apply an appropriate level of security protection.

5.2           We will share your personal information with the following third parties:

(a)        other companies within our group;

(b)        your employer or the relevant Partner (where applicable)

(c)         our regulators, including the Financial Conduct Authority;

(d)        law enforcement agencies in connection with any investigation to help prevent unlawful activity; and

(e)        in the context of the possible sale or restructuring of our business.

5.3           We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party’s to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.              International transfers

We do not transfer your personal data outside the UK.

7.              Data security

7.1           We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.2           We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.              Data retention

8.1           How long will you use my personal data for? We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8.2           To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8.3           By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

8.4           In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

8.5           In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.              Your legal rights

9.1           Under certain circumstances, you have rights under data protection laws in relation to your personal data including:-

(a)        Request access (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.

(b)        Request correction. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c)         Request erasure. This enables you to ask us to delete or remove personal data 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 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.

(d)        Object to processing. You have the right to object to us processing your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e)        Request restriction of processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f)          Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g)        Right to withdraw consent. You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.

9.2           If you wish to exercise any of the rights set out above, please contact us.

9.3           No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9.4           What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.5           Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.