Last Updated: February 2026, v2.2
1. Introduction and Scope
Alba Capital Advisors Limited (“we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information when you use the Assessment Centre - our online assessment platform (the “Platform”).
This Policy applies to all users of the Platform and is incorporated by reference into our Terms and Conditions. By accessing the Platform, you consent to the data practices described in this Policy.
Important Note: This Policy should be read in conjunction with our Terms and Conditions (particularly Version 2.2 dated February 2026), which govern your use of the Platform. Capitalised terms used but not defined herein have the meanings given to them in the Terms and Conditions.
We collect information that you provide directly, information collected automatically, and information from third parties.
- Account Information: Email address, company name, industry, operating country and number of employees when you register.
- Assessment Responses (“Response Data”): All answers you submit through any assessment on the Platform.
- Payment Information: Billing details and transaction history for Paid Assessments. All payments are processed through Stripe, our third-party payment processor. We do not collect, receive, or store your payment card details. Payment confirmations and transaction records are retained for our records.
- Communications: Content of any messages you send to us (e.g., support queries, feedback).
- Usage Data: Information about your interactions with the Platform, including timestamps, pages viewed, buttons clicked, and navigation paths.
- Log and Device Data: As stated in our Terms (Clause 3.3), we record your IP address and its estimated geographical location with every request. We also collect device type, operating system, browser type, and language settings.
- Cookies and Similar Technologies: As detailed in Section 22 of our Terms, we use the following:
- Essential/Functional Cookies: A cookie to store your chosen language preference (locale) if you change it from the system default. This cookie is essential for the functionality of the Platform.
- Microsoft Clarity: We use Microsoft Clarity, an analytics tool provided by Microsoft, to understand how users interact with the Platform. Clarity may place cookies on your device to capture usage data such as mouse movements, clicks, and scrolls. This information helps us identify areas for improvement and focus our development efforts. The cookies set by Microsoft Clarity are outside our control, and their use is governed by Microsoft’s privacy policy. For more information, please visit Microsoft’s Privacy Statement.
- Microsoft .NET Framework: As the Platform is built on Microsoft .NET technologies, your browser may automatically download and store certain files (such as ASP.NET session cookies or temporary files) as part of the .NET Framework’s standard operation. These are necessary for the Platform’s functionality and are outside our control.
- No Marketing Cookies: We do not use any marketing, advertising, or third-party tracking cookies (other than those described above for analytics and essential functionality).
2.3. Managing Cookies
Most web browsers allow you to control cookies through their settings. However, please note that disabling certain cookies (particularly the locale preference cookie or .NET Framework session cookies) may affect the functionality and performance of the Platform, including your ability to complete assessments or maintain language preferences.
We may receive information about you from:
- Analytics Providers: We partner with Microsoft using Clarity to understand website usage. This data is used to improve the Platform and is not used for advertising or shared with third parties for marketing purposes.
- Service Providers: Including our payment processor (Stripe), who provides payment confirmation and fraud risk scores.
We use the information we collect for the following purposes:
| Purpose of Use |
Legal Basis (where applicable) |
| To Provide and Operate the Platform: To create your account, provide assessments, generate your personal Analysis, process payments, and maintain essential functionality (including locale preferences and .NET Framework requirements). |
Performance of our contract with you. |
| To Improve and Develop the Platform: To analyse usage trends, conduct research, and develop new features and assessments. This includes use of Microsoft Clarity analytics to understand user behaviour and focus development efforts. |
Our legitimate interest in improving our services. |
| For Benchmarking and Trend Analysis: To create aggregated, anonymized industry and geographical benchmarks, and to identify emerging trends as described in our Terms (Clause 5). This use involves irreversible anonymization. |
Our legitimate interest in providing benchmarking services and industry insights. |
| For Security and Integrity: To monitor for security breaches, fraud, and abuse (as per Clause 3.3 of the Terms), and to enforce our Terms and Conditions. |
Our legitimate interest in protecting our Platform and users. |
| For Communication: To send you service-related announcements (e.g., updates, security alerts) and, with your consent/where permitted by law: (i) Commercial Outreach about potential commercial opportunities (Clause 6 of Terms); and (ii) Assessment Update Notifications if you have opted in (Clause 7 of Terms). |
Legitimate interest (service messages) / Consent (marketing and notifications). |
| For Customer Support: To respond to your inquiries and provide support. |
Performance of our contract with you / Our legitimate interest. |
We do not sell your personal information. We share it only in the following circumstances:
- With Your Consent: For example, if you agree to be introduced to a partner. We currently do not have any such partnerships, but may in the future. We will always seek your explicit consent before sharing your information with any third party for this purpose.
- With Service Providers (“Processors”): We engage trusted third parties to perform functions like cloud hosting (in Asia), payment processing (Stripe), data analytics (Microsoft Clarity), customer support, and email delivery. They process your data only on our instructions and are bound by contractual obligations of confidentiality and security.
- For Legal & Compliance Reasons: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests; to protect the rights, property, and safety of us, our users, or the public; to enforce our Terms; or for fraud prevention.
- Business Transfers: In connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.
- As Aggregated and Anonymized Data: We share industry reports and benchmark data that are based on aggregated, anonymized information that cannot reasonably be used to identify you. This is our proprietary data as per Clause 4.2 of the Terms.
5. International Data Transfers
Our primary cloud servers are located in Asia. If you are located outside Asia, your personal information will be transferred to and processed in Asia and potentially other jurisdictions where our service providers operate. These countries may have data protection laws that differ from your home country.
We implement appropriate safeguards (such as Standard Contractual Clauses approved by relevant authorities) to ensure your data remains protected in accordance with this Privacy Policy and applicable law when transferred internationally.
6. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law, or to comply with future compliance or legal obligations.
- Account Data: Retained for the life of your account. You may request deletion.
- Response Data and Analysis: Retained indefinitely to provide you with ongoing access to your historical Analysis and for our benchmarking purposes, as described in Clause 5.1 of the Terms. This includes retention of prior versions of your responses and corresponding Analyses if you edit a completed questionnaire (as described in Clause 2.5). This data is critical to our service model and benchmarking integrity.
- Log Data (IP Addresses): Retained for a period necessary for security monitoring, fraud prevention, and legal compliance, typically for a minimum of 12 months.
- Marketing Preferences: We retain a record of your opt-out choices indefinitely to ensure we do not contact you if you have asked us not to.
7. Your Rights and Choices
Depending on your location, you may have certain rights regarding your personal information:
- Access & Portability: Request a copy of the personal data we hold about you.
- Correction: Update or correct inaccurate data.
- Deletion: Request deletion of your personal data, subject to certain legal exceptions (e.g., where we need to retain it for legal compliance or the establishment, exercise, or defence of legal claims, or for benchmarking integrity as described in our Terms).
- Restriction & Objection: Object to our processing or request a restriction on processing in certain circumstances.
- Withdraw Consent: Where processing is based on consent, you may withdraw it at any time (including for Assessment Update Notifications and Commercial Outreach).
- Opt-Out of Marketing: Unsubscribe from marketing emails via the link in every email or in your account settings.
To exercise these rights, please contact us using the details in Section 13. We will respond in accordance with applicable law. We may need to verify your identity before processing your request.
8. Data Security
We implement appropriate technical and organisational measures (including encryption, access controls, and secure cloud infrastructure) to protect your personal information from unauthorised access, disclosure, alteration, or destruction. However, no internet transmission or electronic storage method is 100% secure. We cannot guarantee absolute security.
You are responsible for keeping your account credentials confidential. If the Platform uses one-time passwords for authentication, you should not share these with anyone. If you believe your account has been compromised, please contact us immediately.
9. Our Use of AI and Automated Processing
This section is a key component of our Policy and relates directly to our Terms.
- Analysis Generation: As stated in Clause 2.2 of the Terms, your Analysis is generated using our proprietary “Clara” framework, which may utilise public and private Large Language Models (LLMs) and other AI technologies. This involves automated processing of your Response Data.
- Translations: If you use the Platform in a language other than UK English, both the questionnaire interface and your responses may be translated using AI LLMs, as detailed in Clause 2.4 of the Terms. You acknowledge that for the purpose of generating the Analysis: (i) your responses will be translated into UK English; (ii) analytical processing will be conducted on the UK English translation; and (iii) the final Analysis will be presented in UK English. This translation process may alter, nuance, or otherwise affect the substance of your responses and, consequently, the resulting Analysis.
- Impact: You acknowledge that the AI-driven nature of these processes means outputs are interpretative and indicative, not definitive facts. Please review the Disclaimers in Section 8 of the Terms.
10. Children’s Privacy
The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us. We will take steps to delete such information.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The “Last Updated” date at the top will indicate when changes were made. We will notify you of material changes via email or a prominent notice on the Platform before the change becomes effective. Your continued use of the Platform after such notification constitutes your acceptance of the revised Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:
Alba Capital Advisors Limited
Email: support@zeropro.co
13. ANNEX: Definitions
- “Personal Information” means any information relating to an identified or identifiable individual.
- “Processing” means any operation performed on personal information, such as collection, storage, use, or disclosure.
- “Anonymized Data” means data that has been processed in such a way that it can no longer be attributed to a specific individual without the use of additional information, which is kept separately and subject to technical and organisational measures to ensure non-attribution.
- “Controller” means the entity that determines the purposes and means of processing personal information (i.e., Alba Capital Advisors Limited).
- “Response Data” means the raw data you input as responses to questionnaires on the Platform.
- “Analysis” means the generated report and insights produced based on your Response Data.