Privacy Policy
Elevate Online Marketing 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 when you visit our website (regardless of where you visit it
from) 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. Please also use the Glossary to understand
the meaning of some of the terms used in this privacy policy.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Elevate Online
Marketing collects and processes your personal data through your use of this
website, including any data you may provide through this website when you
purchase a product or sign up to our Newsletter or register your interest or
details for any of our other services or offerings from time to time.
This website is not intended for children and we do not knowingly collect data
relating to children. If we believe that children are using our website and
attempting to use our services we will take all reasonable and necessary
steps to check and properly manage the position.
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.
Controller
Elevate Online Marketing Ltd, Company number 11333076 (registered office
address Court Hall, Castle Street, Trowbridge, Wiltshire, BA14 8AR) is the
controller and responsible for your personal data (collectively referred to as
“COMPANY”, “we”, “us” or “our” in this privacy policy) and responsible for this
website.
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy policy. If you have any questions about this
privacy policy, including any requests to exercise your legal rights, please
contact the data privacy manager using the details set out below. Contact details
If you have any questions about this privacy policy or our privacy practices,
please contact our data privacy manager in the following ways:
Data Privacy Manager: Samuel David Griffin Griffin
Full name of legal entity: Elevate Online Marketing Ltd.
Email address: [email protected]
Address: Court Hall, Castle Street, Trowbridge, Wiltshire, BA14 8AR
Telephone number: 0800 69 06 009
You have the right to make a complaint at any time to the Information
Commissioner’s Office (ICO), the UK supervisory authority 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.
Changes to the privacy policy and your duty to inform
us of changes
We keep our privacy policy under regular review. This version was last
updated on 6th May 2019. Historic versions can be obtained by contacting us.
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.
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 web
2. The data we collect about you
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:
● Identity Data includes first name, last name, username or similar
identifier.
● Contact Data includes billing address, delivery address, email address
and telephone numbers.
● Financial Data includes bank account details if provided
● Transaction Data includes details about payments to and from you and
other details of products and services you have purchased from us.
● 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.
● Profile Data includes your purchases or orders made by you, your
interests, preferences, feedback and survey responses.
● Usage Data includes information about how you use our website,
products and services
● Marketing and Communications Data includes your preferences in
receiving marketing from us and our third parties and your
communication preferences updated as required.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived from
your personal data but is not considered personal data in law as this data will
not directly or indirectly reveal your identity. For example, we may aggregate
your Usage Data to calculate the percentage of users accessing a specific
website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with this
privacy policy.
We do not collect any Special Categories of Personal Data about you (this
includes details about your race or ethnicity, religious or philosophical beliefs,
sex life, sexual orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
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?
● Direct interactions. You may give us your Identity, Contact and Financial
Data by filling in forms on our website or corresponding with us by post,
phone, email or otherwise. This includes personal data you provide
when you:
○ apply for our products or services;
○ 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.
● 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 and other similar technologies. Please see our cookie
policy for further details.
● Third parties or publicly available sources. We will receive personal data
about you from various third parties as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Google, unbounce and iContact based
outside the EU; and
(c) search information providers such as Google based outside the EU.
4. How we use your personal data
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:
● Where we need to perform the contract we are about to enter into or
have entered into with you.
● 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.
● Where we need to comply with a legal obligation.
See below to find out more about the types of lawful basis that we will rely on
to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your
personal data although we will get your consent before 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.
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 bases we rely on to do so.
We have also identified what our legitimate interests are where appropriate.
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.
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 from us and you have not opted out
of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data
with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at
any time by logging into the website and checking or unchecking relevant
boxes to adjust your marketing preferences OR by emailing us on
[email protected] or by opting out of the marketing emails using the
Unsubscribe facility when you receive them.
Where you opt out of receiving these marketing messages, this will not apply
to personal data provided to us as a result of a service or product purchase,
warranty registration, product/service experience or other transactions where
we need the information to deliver the service for which you have engaged us.
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.
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 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
We may share your personal data with the parties set out below for the
purposes set out in the table in Section 4 Purposes for which we will use your
personal data above.
● External Third Parties as set out in the Glossary in 10 below.
● Specific third parties listed in the table in Section above.
● Third parties to whom we may choose to sell, transfer or merge parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business,
then the new owners may use your personal data in the same way as
set out in this privacy policy.
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 service
providers 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
Many of our external third parties are based outside the EEA so their
processing of your personal data will involve a transfer of data outside the
EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
● Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data the
same protection it has in Europe. For further details, see European
Commission: Model contracts for the transfer of personal data to third
countries.
● Where we use providers based in the US, we may transfer data to them
if they are part of the Privacy Shield which requires them to provide
similar protection to personal data shared between Europe and the US.
For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism
used by us when transferring your personal data out of the EEA.
7. Data security
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.
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
How long will you use my personal data for?
By law we have to keep some basic information our customers (including
contact, identity, financial and transaction data) for 6 years after they cease
being customers for tax purposes but subject to this:-
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 of our
relationship with you.
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.
In some circumstances you can ask us to delete your data: see your legal
rights below for further information.
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
Under certain circumstances, you have rights under data protection laws in
relation to your personal data. Please see below to gain more information on
this.
If you wish to exercise any of the rights set out above, please contact our data
privacy manager the details for whom appear in section 1 of this policy.
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.
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.
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
10. Glossary
LAWFUL BASIS
Legitimate Interest 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 usa599551.
Performance of Contract means processing your data where it is necessary
for the performance of a contract to which you are a party or to take steps at
your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it
is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties
● Service providers acting as developers and processors based in India
and Serbia who provide IT, system administration and website
development services.
Professional advisers some acting as processors or joint controllers including
lawyers, bankers, auditors and insurers based in the EU who provide
consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom who require
reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (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.
Request correction of the personal data that we hold about you. 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.
Request erasure of your personal data. 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.
Object to processing of 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.
Request restriction of processing of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following
scenarios:
● If you want us to establish the data’s accuracy.
● Where our use of the data is unlawful but you do not want us to erase it.
● 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.
● You have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
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.
Withdraw 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.
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