Privacy Policy

Last updated: 30 October 2026

1. Who is responsible for your data

The controller of the personal data described in this policy is Zoom Riddle, [legal entity name, registered address and registration number – to be completed before launch].

You can reach us on hello@zoomriddle.com for any question about this policy or to exercise your rights. If we appoint a Data Protection Officer, their details will appear here.

This policy applies to zoomriddle.com, including our contact form, our subscription form for The Riddle Ledger, and the cookies and similar technologies used on the site. We collect little data and only for the purposes below.

2. What we collect, why, and on what legal basis

2.1 Register-your-interest form

When you write to us through the contact form, we receive the details you choose to enter: first name, last name, job title, company, email address, telephone number, LinkedIn profile and your message. We use them to reply to you and, where relevant, to discuss a possible engagement.

Legal basis: our legitimate interest in answering business enquiries, and steps taken at your request before entering into a contract (Article 6(1)(f) and 6(1)(b) GDPR).

2.2 Subscription form (The Riddle Ledger)

When you subscribe, we receive the same type of details (name, job title, company, email address, and optionally telephone number and LinkedIn profile) together with your opt-in choice. We use them to send you The Riddle Ledger and related updates by email.

Legal basis: your consent (Article 6(1)(a) GDPR). You can withdraw it at any time using the unsubscribe link in every email, or by writing to us. Brevo reports to us whether an email was opened and whether its links were clicked, so that we can see which perspectives are read.

2.3 Emails you send us

If you email us directly, we keep your message and our reply so that we can follow up. Legal basis: legitimate interest and pre-contractual steps, as in 2.1.

2.4 Spam protection with Google reCAPTCHA

Our contact and subscription forms are provided by Brevo and protected by Google reCAPTCHA, which tells humans from automated bots. When reCAPTCHA loads, Google receives technical information from your browser, such as your IP address, browser and device data, cookies, and how you interact with the page, in order to assess whether you are a human visitor. This processing is governed by Google’s Privacy Policy and Terms of Service.

reCAPTCHA is loaded only after you accept cookies in our cookie banner. If you decline, the forms cannot be submitted; you can write to us at hello@zoomriddle.com instead, or change your choice at any time through cookie preferences.

Legal basis: your consent to loading the service (Article 6(1)(a) GDPR and the ePrivacy rules) and our legitimate interest in keeping the forms secure and free of abuse (Article 6(1)(f)).

2.5 Website analytics (Google Analytics 4)

With your consent, we use Google Analytics 4, connected through Google Site Kit, to understand how the site is used: pages viewed, time on page, referring website, approximate location, and device and browser type. Google Analytics 4 does not log or store IP addresses. The service is not loaded until you accept statistics cookies.

Legal basis: your consent (Article 6(1)(a) GDPR).

2.6 Fonts

The site uses fonts served by Google Fonts. Fetching them sends your IP address to Google. Fonts are loaded only after you accept cookies; until then, your browser shows fallback fonts. Legal basis: your consent.

2.7 Server logs

Our hosting provider’s servers automatically record technical data such as IP address, date and time, requested page and browser type, for the security and operation of the site. Legal basis: our legitimate interest in running and securing the site.

3. Who receives your data

We do not sell your personal data and we do not use it for advertising profiling. We share it only with the service providers that help us run the site, acting on our instructions or under their own privacy terms:

  • Brevo (Sendinblue SAS, Paris, France): hosts the contact and subscription forms, stores contact records, and sends emails and newsletters.
  • Google (Google Ireland Limited for users in the European Economic Area; Google LLC, United States): Google reCAPTCHA, Google Analytics 4 and Google Fonts.
  • Hosting provider: [hosting company name and country – to be completed before launch].
  • Professional advisers and authorities, where we are required to share data to comply with the law or to establish or defend legal claims.

4. Transfers outside the European Economic Area

Brevo stores data in the European Union. Google may process data in the United States and other countries; such transfers rely on the European Commission’s adequacy decision for the EU–US Data Privacy Framework, or on standard contractual clauses and the other safeguards offered by the provider. Where a provider uses sub-processors outside the EEA, equivalent safeguards apply. You can ask us for more information on these safeguards at any time.

5. How long we keep your data

DataRetention
Contact enquiries and correspondenceUp to 3 years after our last exchange with you, unless a business relationship or legal obligation requires longer.
Newsletter subscribersUntil you unsubscribe or withdraw consent; contacts with no interaction for 3 years are reviewed and deleted. A minimal record may be kept to honour your unsubscription.
Analytics data (Google Analytics 4)[retention period set in the Google Analytics account, 14 months maximum – to be confirmed]
Cookies and consent choiceAs listed in our Cookie Policy.
Server logs[period applied by the hosting provider – to be confirmed]

6. Cookies and similar technologies

We use cookies and similar technologies only as described in our Cookie Policy. Cookies that are not strictly necessary are placed only after you consent. You can accept, refuse or change your choice at any time through cookie preferences.

7. Your rights

Under the General Data Protection Regulation (and, where applicable, the UK GDPR and the Swiss data protection act) you have the right to:

  • access the personal data we hold about you and receive a copy;
  • have inaccurate data corrected or incomplete data completed;
  • have your data erased, in the cases provided by law;
  • restrict the processing of your data;
  • object to processing based on our legitimate interest;
  • receive the data you provided in a portable, machine-readable format;
  • withdraw your consent at any time, without affecting the lawfulness of processing carried out before; and
  • give instructions about what happens to your data after your death (France).

To exercise any of these rights, email hello@zoomriddle.com. We may ask you to confirm your identity, and we will reply within one month.

If you believe we have not handled your data properly, you have the right to lodge a complaint with the French data protection authority, the Commission Nationale de l’Informatique et des Libertés (CNIL), or with the supervisory authority where you live or work.

8. Providing your data

Submitting a form is voluntary. Without the details marked as required on the form, we cannot answer your enquiry or send you the newsletter. We do not take decisions based solely on automated processing that produce legal effects on you.

9. Security

We apply appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS) and restricted access to our systems. No method of transmission over the internet is completely secure, but we work to protect your information.

10. Children

This site is intended for business professionals. It is not directed at children, and we do not knowingly collect their personal data.

11. Links to other websites

Our pages may link to third-party websites, such as LinkedIn. Those sites have their own privacy policies, and we are not responsible for how they handle your data.

12. Changes to this policy

We may update this policy from time to time. The date of the latest version is shown at the top of this page. Where a change is significant, we will make it visible on the site.