Last Updated: 04-01-2020
Elite Digital (“Elite Digital” / “Elite” / “we” / “our” / “us”) are committed to protecting and
respecting your privacy.
This policy sets out the basis on which we will process any personal data we collect from you or that you or that you provide to us through your use of the Elite Digital online software platform and the accompanying software (together the “Platform”). Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting https://goelitedigital.co.uk or using the Platforms you are accepting and consenting to the practises described in this policy.
INFORMATION WE COLLECT ABOUT YOU
We will collect and process the following data about you:
Information you give us
You may give us information about you: when using the Platform’s functions, including by filling in forms or completing surveys on or via the Platform. This information may include your name, age, email address and location or otherwise using the Platform; if you contact or correspond with us (for example, using any support function made available by us) and we may keep a record of that correspondence (either directly or through our service providers). Information you give us. You may give us information about you: when creating a user profile for you in order to enable you to access the Platform under the Business License Agreement or to enable us to send engagement surveys and similar communications to you. This information may include your name, age, email address and location.
Information we collect about you
Each time you contact us or otherwise use the Platform we may automatically collect the following information:
when you use the Platform, we will keep a record of the details of that usage, including the date, time, location, frequency and duration of the usage; we may obtain further information about you, for example to verify your eligibility to access and use the Platform; any comments, opinions and/or feedback you provide to us regarding the Platform, technical information about your computer or mobile device for system administration and analysis, including your IP address, URL clickstreams, unique device identifiers, operating system, and network and browser type; other information about your use of the Platform, including the pages you have viewed, the duration spent on the Platform and data files you have uploaded to the Platform. This information may be linked to your user profile (where relevant).
Information we receive from other sources
We work closely with third parties (including for example, business partners, other companies, subcontractors and analytics providers) and may receive information about you from them.
HOW WE USE YOUR INFORMATION
Please note, we are permitted to collect, use, disclose and/or otherwise process any data or information other than personal data, including data sets you upload to the Platform or otherwise provide to us, to the fullest extent permitted by the Business License Agreement.
We may use the personal information we hold about you in the following ways:
Information you give to us. We will use this information to:
- process your application to become a registered user of the Platform and verify your eligibility to use the Platform;
- carry out our obligations arising from the Business License Agreement. This includes providing reports and analysis summarising information provided during your use of the Platform, including in any engagement surveys, aggregated with information from you and your clients. Data you provide to us will never be used to personally identify you, unless you explicitly choose otherwise. All survey responses are entirely optional. We will not contact you for promotional or marketing purposes, such as to inform you of new products or services that we offer, unless you specifically consent to this at the time you provide your details to us or you expressly request (or provide explicit consent for) us to do so at a later date
- contact you for your feedback on our services and to help us evaluate and improve our services, for example by acting on any information you have provided to us
- notify you about changes to the Platform and any other services of ours that you use, including informing you about new versions of the Platform and about new features, functionality and service offerings; or
- deal with any enquiries, correspondence, concerns or complaints you have raised, or that have been raised by or concerning third parties (such as your employer) involving you and any issues caused by your use of the Platform.
Information we collect about you. We will use this information:
- to administer and improve the Platform and other services, including ensuring that content is presented in the most effective manner for you and for your computer;
- for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to allow you to participate in interactive features of the Platform, when you choose to do so;
- as part of our efforts to keep the Platform safe and secure; or
- to compile reports (which do not personally identify you) of usage of the Platform.
Information we receive from other sources. We may combine information from other sources with the
you give to us or we collect about you and use this information as specified above.
We will not undertake any surveys or analysis via the Platform by reference to any of the following special
of personal data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union
membership, genetic or biometric data, health data, sex life or sexual orientation.
Data collected from you and other employees or personnel may be used by us in an aggregated and anonymised form for statistical and benchmarking purposes including enabling comparisons to other organisations within the same industry.
DISCLOSURE OF YOUR INFORMATION
We may share your personal data with other companies we work with. We may also share your personal information with selected third parties in accordance with this policy, including:
- service providers, for example of IT services, business partners, suppliers and/or sub-contractors, for the performance of any contract that we enter into including: Amazon Web Services, Inc Google, Inc;
- analytics and search engine providers that assist us in the improvement and optimisation of our site and the analysis of data supplied via the Platform, including Google Analytics; and
- government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information).
We may disclose your personal information to other third parties:
- if we sell or buy any business assets or receive investment into our business, we may disclose your personal data to the prospective or actual buyer, seller or investee of such business or assets;
- if Elite Digital or substantially all of its assets are acquired by a third party, in which case personal data held by us, including your data and data about our customers, suppliers and correspondents will be one of the transferred assets;
Except as explained above, we will not disclose your personal data to any third parties for any other purpose unless we have a legal right or obligation to do so.
We require our service providers to comply with data protection laws whenever they process your personal
and not to disclose your data to third parties without our express consent.
INTERNATIONAL DATA TRANSFERS
The information that we collect from you may be transferred to, processed and stored at, a destination outside the European Economic Area ("EEA") where required to support certain models and features of the Platform and/or to fulfil obligations in the Business License Agreement. We will only transfer your personal data outside the EEA where we have your consent to do so.
SECURITY OF INFORMATION
You will require a username and password to gain access to the Platform. Where we have given you a username, password and/or security information which enables you to access particular features of the Platform, you are responsible for keeping these access credentials confidential. You must not share these details with anyone, or store them in a way that may allow a third party to access them.
We maintain appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features which are appropriate to the type of personal data you have provided to try to prevent unauthorised access or inadvertent disclosure, which may include two factor authentication and end-to-end encryption.
STATUS OF THIS POLICY AND YOUR CONSENT
Where consent is required for our use of your information, by ticking the appropriate consent box or otherwise communicating your consent to us (whether by phone, email or other means), you consent to our use of that information as set out in this policy. If you disclose someone else's information to us, you confirm that you have their consent to disclose this information to us and for us to use and disclose it in accordance with this policy.
RETAINING YOUR INFORMATION
We will retain the personal information we receive and collect about you for a period of 8 years. After this period, your personal data will be anonymised. We will not store your personal data for longer than is reasonably necessary to use it in accordance with this policy or with our legal rights and obligations. For the avoidance of doubt, aggregated and anonymised data and any information other than personal data can be stored indefinitely.
You have the following rights in regards to your personal information:
You have the right to access information about the personal data we hold about you. We reserve the right to charge a reasonable fee in response to unreasonable or repetitive requests, or requests for further copies of the same information.
Right to object to processing
You have the right to object to processing of your personal data where that processing is being undertaken by us on the basis of our (or a third party’s) legitimate interest. In such a case we are required to cease processing your data unless we can demonstrate compelling grounds which override your objection. You also have the right to object at any time to the processing by us of your personal data for direct marketing purposes.
You have the right to request that we rectify any inaccurate personal data that we hold about you.
You have the right to obtain copies of your personal data to enable you to reuse your personal data across different services and with different companies. You may also request that your personal data is transmitted directly to another organisation where this is technically feasible using our data processing systems.
Change of preferences
You can change your data processing preferences at any time. For example, if you have given your consent to direct marketing, but have changed your mind, you have the ability to opt out of receiving marketing communications by emailing us at email@example.com or clicking the relevant link in any communication you receive.
Please note, if you submit a request for us to stop processing your personal data in a certain way and this type of processing is required in order to facilitate your use of the Platform, you will no longer be able to use the Platform following your request to stop the relevant processing (this does not include your right to object to direct marketing which can be exercised at any time without restriction). Please allow at least 5 working days for your request to be actioned.
Objections and Complaints
In certain circumstances you have the right to object to our processing of your personal data. If for any reason you are not happy with the way that we have handled your personal information, you also have the right to make a complaint to the Information Commissioner’s Office. Save as set out above, your rights detailed above can be exercised free of charge in accordance with applicable data protection laws. Please contact your employer directly if you would like to exercise any of these rights (other than a change to your marketing preferences, which should be notified directly to us as described above).
COMPANY AND DATA PROTECTION INFORMATION
The data controller of data on the goelitedigital.co.uk is Elite Digital Limited, a company registered in England under company number 12337350, whose registered office is at 141 Clough Lane, Brighouse, England, HD6 3QP. Any queries or notices under the Data Protection Act should be sent to the above address.