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ELITE COMMUNICATIONS UK LTD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits any of our websites and will only collect and use personal data in ways that are described herein and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account we create in order for you to access and/or use certain areas and features of our website;
“Cookie” means a small text file placed on your computer or device by our website when you visit certain parts of our website and/or when you use certain features of our website. Details of the Cookies used by our website are set out in Part 14 below; and
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
Our website is owned and operated by ELITE COMMUNICATIONS UK LIMITED; a Limited Company registered in England and Wales under company number 02651979.
- Registered address: Office 112, Sutton Point 6 Sutton Plaza, Sutton, London, United Kingdom, SM1 4FS
- VAT number: GB560518255.
- Data Protection Officer: Nuria@elite-comms.com Telephone number, 02033623018
- Postal Address: Data Protection Officer, Nuria, Office 112, Sutton Point 6 Sutton Plaza, Sutton, London, United Kingdom
- We are regulated by Phone-paid Services Authority.
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please note that transaction data must be stored for a minimum of seven years in the UK. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
Depending upon your use of our website, we may collect some or all of the following
- Date of birth;
- Email address;
- Telephone and Mobile number(s);
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on our website, and the site you exit to;
- A copy of your Identification, only if sent directly from yourself.
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for any of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to our website;
- Personalising and tailoring your experience on our website;
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you (you may unsubscribe or opt-out at any time by following the instructions contained within the communication or by contacting us using the details in Part 15).
- Supplying you with information by email and/or post and/or SMS that you have opted-in to (you may unsubscribe or opt-out at any time by following the instructions contained within the communication or by contacting us using the details in Part 15).
- Analysing your use of our website and gathering feedback enables us to continually improve our website and your user experience.
- Determining whether you are authorised to access our services based on risk.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You will always have the opportunity to opt out.
Third Parties (including, but not limited to: Google and Facebook) whose content appears on our website may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
The following automated decision-making method(s) may be used:
- When initiating a transaction, we may verify your data against an internal and/or external system in order to determine the risk factor of each transaction. If the transaction is deemed to be of risk, we may restrict your ability to proceed with a transaction. In most cases, we are able to lift this restriction with a copy of your Identification along with a cover letter, should you wish to provide this.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Transaction data is retained for a minimum of seven years from the date of transaction.
9. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”) and the United States of America (the “USA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. Within the EEA, your data will be fully protected under the GDPR. Where we transfer your data to a third party based in the USA, we will share the data with third parties who are part of the EU-US Privacy Shield. This requires that a third party provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Your transaction data is stored within a high-security Data Centre in England. The Data Centre is ISO/IEC 27001 compliant and has perimeter fencing, CCTV coverage, 24- hour manned security and a strict Photo ID and swipe card entry system. Your physical payment card data is processed and/or stored by a third-party PCI Level 1 compliant Service Provider within the EEA.
10. Do You Share My Personal Data?
We contract with the following third parties to supply certain products and/or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some of your personal data that we hold.
- Google (USA) – Analysis of your activity whilst interacting with one of our Websites.
- Facebook (USA) – Improve customer experience.
- Global Payments) (EEA) – PCI Compliant Payment Processor.
If any of your personal data is required by a third party, as described above, we always take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5 when you submit personal data via our website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and/or text messages
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications you have consented to receive.
12. Can I Withhold Information?
You may access certain areas of our website without providing any personal data at all. However, to use all features and functions available on our website, you may be required to submit or allow for collecting certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests), a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data, within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using our website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our site for analytics purposes only. For more details, please refer to the table below. These Cookies are not integral to the functioning of our website, and your use and experience of our website will not be impaired by refusing consent to them.
All Cookies used by and on our website are used in accordance with current Cookie Law.
Certain features of our website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
Name of Cookie
Handles your interaction with our website.
Our website uses analytics services provided by Google (USA). Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to understand better how our website is used. This, in turn, allows us to improve our website and the services offered through it.
The analytics service(s) used by our website use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies; however, whilst our use of them does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our service, making it a better and more useful experience for you.
The analytics service(s) used by our website use(s) the following Cookies:
Name of Cookie
ga, gid, gat, PHPSESSID
First / Third Party
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also allow you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time. However, you may lose any information that enables you to access Our Site more quickly and efficiently, including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details, Nuria: Email address: email@example.com Telephone number: 0203 362 3018
- Postal Address: Office 112, Sutton Point 6 Sutton Plaza, Sutton, London, United Kingdom, SM1 4FS
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes or if we change our business in a way that affects personal data protection.