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Privacy Policy

Operated by: Circle2 Ltd.

Registered Address: 138 Harrow View, Harrow, HA1 4TJ, United Kingdom

Company Number: 15060597

Email: [email protected]

This Privacy Policy describes how Zyra - www.zyra.business ("we," "us," or "our"), operated by Circle2 Ltd., collects, uses, and discloses information when you use our website and services.

We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy complies with the UK General Data Protection Regulation (GDPR), and acknowledges principles from the California Consumer Privacy Act (CCPA) and California Online Privacy Protection Act (CalOPPA) due to our global user base.

1. Information We Collect

We collect the following types of personal information:

  • Personal Identifiers:
    • First Name and Email Address: Collected via website forms when you apply for our program or communicate with us.
  • Transaction Data:
    • Payment Information: Collected via our third-party payment processor, Stripe, when you make a payment for our services. We do not directly store your full payment card details.
  • Usage Data:
    • Website Usage Information: Collected through our local Odoo analytics system (hosted on our own server), which tracks interactions with our website to help us understand how it's used and improve your experience. This data is kept local and is not shared with external analytics tools or businesses.

We do not currently use cookies or similar tracking technologies on our website.

2. How We Use Your Information

We use the information we collect for the following purposes:

  • To Provide and Manage Services:
    • To process your program application.
    • To communicate with you regarding your application, program progress, and services.
    • To provide you with access to the "Do It Yourself - Better Business Program."
    • To process your payments for programs and services via Stripe.
    • To send you email marketing communications and transactional emails via MailerLite.
    • To manage general business communications via Zoho Email.
  • For Analytics and Improvement:
    • To analyze website usage patterns to improve the design, content, and functionality of our website and services (using our local Odoo analytics).

3. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal data based on the following legal grounds:

  • Contractual Necessity: To fulfill our obligations under a contract with you, such as providing program access or linked services.
  • Legitimate Interests: To improve our website and services, conduct business operations, and for direct marketing where we have assessed that our interests do not override your rights and freedoms.
  • Consent: In specific cases, we may rely on your explicit consent for certain processing activities, particularly for marketing communications where required. You have the right to withdraw your consent at any time.

4. How We Share Your Information

We share your information with the following third parties, strictly for the purposes described:

  • Stripe: For secure payment processing. When you make a payment, your financial data is handled directly by Stripe.
  • MailerLite: For sending email marketing campaigns and essential transactional emails related to your account and program.
  • Zoho Email: For our primary business email communication services.

Please note: Our Odoo analytics data is hosted on our own server and is not shared with any external third parties.

We will not sell or rent your personal information to third parties for their marketing purposes. We may disclose your information if required by law or in response to valid requests by public authorities.

5. Data Retention

We retain your personal information for as long as necessary to provide you with our services and fulfill the purposes outlined in this Privacy Policy.

  • Personal Identifiers (Name, Email): Retained as long as you have an active account or are receiving our services/communications. If you request account deletion or cessation of services, we will remove your data, subject to any legal obligations to retain certain information (e.g., for tax or legal compliance).
  • Payment Information: Retained by Stripe in accordance with their policies and legal requirements.
  • Usage Data (Odoo Analytics): Retained indefinitely for the purpose of long-term trend analysis and continuous improvement of our website and services.

6. Data Security

We implement robust technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

  • Encryption: Using encryption protocols for data transmission and storage where appropriate.
  • Access Controls: Restricting access to personal data to authorized personnel only.
  • Secure Servers: Hosting our website and Odoo analytics on secure servers.

7. International Data Transfers

As our users come from the USA and worldwide, and we utilize services like Stripe and MailerLite (which may process data outside the UK/EEA), your information may be transferred to, and stored in, countries outside of your own. We ensure that any such transfers comply with applicable data protection laws by relying on appropriate safeguards (e.g., Standard Contractual Clauses, or ensuring the recipient has adequate data protection mechanisms in place).

8. Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data. You can exercise any of these rights by contacting us at [email protected]:

  • Right of Access: You have the right to request a copy of the personal data we hold about you.
  • Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
  • Right to Erasure ("Right to Be Forgotten"): You have the right to request the deletion of your personal data under certain circumstances.
  • Right to Restriction of Processing: You have the right to request that we limit the way we use your personal data.
  • Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller.
  • Right to Object: You have the right to object to the processing of your personal data in certain situations, particularly concerning direct marketing.

You also have the right to lodge a complaint with the relevant supervisory authority. In the UK, this is the Information Commissioner's Office (ICO).

9. Children's Privacy

Our website and services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal data from a child under 18 without parental consent, we will take steps to remove that information.

10. Data Breach Notification

We are committed to maintaining the security of your data. While we do not currently have a formal data breach notification process in place as we have no users, we will implement such a process before reaching 1,000 users. In the event of a data breach, we will take appropriate steps to mitigate the impact and notify affected parties and regulatory authorities as required by applicable laws.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new policy on our website. Your continued use of the website after such changes constitutes your acceptance of the revised Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: [email protected]

Address: 138 Harrow View, Harrow, HA1 4TJ, United Kingdom