BACKGROUND:
ELESMA LTD. (“Elesma”) 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 this website, https://www.Elesma.co.uk/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site and/or You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
| “Account” | means an account required to access and/or use certain areas and features of Our Site; |
| “Cookies” | means a small text or other file placed on your computer by Our Site when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies and/or JWT used by this Website are set out in Part 14, below; and |
| “Cookie Law” | means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011; and all/any applicable law covering the use of JSON Wen Tokens (“JWT) |
| “User / Users” | means any third party that accesses browses, crawls, scrapes, or in any way uses Our Site and is not employed by The Company and acting in the course of their employment; and |
| “Website / Our Site” | means the website that you are currently using and any sub-domains of this site including all/any mobile applications (Apps) that link to or reference these Terms unless expressly excluded by their own terms and conditions |
2. Information About Us
Our Site is owned and operated by Elesma Ltd. (“Elesma”) whose business address is at First Floor, 202 Kensington Church Street, London, W8 4DP, United Kingdom. Our Data Protection Officer is Kyriacos Kyriacou who may be contacted by email at: info@elesma.co.uk
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
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:
5.1 – The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
5.2 – The right to access the personal data we hold about you. Part 13 will tell you how to do this.
5.3 – 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.
5.4 – 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 contact us using the details in Part 15 to find out more.
5.5 – The right to restrict (i.e. prevent) the processing of your personal data.
5.6 – The right to object to us using your personal data for a particular purpose or purposes.
5.7 – 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.
5.8 – Rights relating to automated decision-making and profiling. we do not use your personal data in this way.
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 (https://ico.org.uk/ ) 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?
If you simply browse our site we will not collect data about you. If however you contact us via our website, make an enquiry about using our services or retain us to provide services for you or for your organisation we will collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies):
- Date of birth;
- Gender;
- Address;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Profession;
- Payment information;
- Other personal and non-personal data necessary for the work you require
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 will be used for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and/or services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing our Data Protection Officer email at: info@elesma.co.uk asking to unsubscribe or opt-out).
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, telephone, text message and/or post with information, news, and offers on our products and/or 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 applicable law including Cookie Law and you will always have the opportunity to opt-out.
We do not use automated systems for carrying out certain kinds of automated decision-making and/or automated profiling. If however at any point we decide to use such a system you will have the right to query any action that we take on the basis of this or 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 us to find out more using the details in Part 15.
8. How Long Will You Keep My Personal Data?
We will usually keep your data for at least 6 years but 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. The following factors will be used to determine how long it is kept:
- We will regularly review the personal data we hold, and delete anything we consider is no longer needed.
- If/When establishing any standard retention periods for different categories of information, we will take account of any professional rules or regulatory requirements that apply.
- We will from time to time conduct an audit to check through the records we hold to make sure we are not holding onto personal data for too long, or deleting it prematurely.
- Personal data will need to be retained for longer in some cases than in others.
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”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. If however the work for which you have retained us requires your data to be transferred to any party outside of the EEA (these are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA). In that event we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK, the EEA and under the GDPR.
10. Do You Share My Personal Data?
If we ever need to share your data with third parties, e.g. for payment processing or other necessary reason we will 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.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if for example we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may need to share your data with third parties as may be necessary for the proper performance of our services for you. For example we may need to instruct a barrister (“Counsel”) or an expert; or to discuss your case with witnesses or to share your data with the courts or tribunals or arbitrators.
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 Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you control over 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 at the point of providing your details and by managing your Account if applicable.
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 receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
You may access Our Site without providing any personal data at all. However, to contact us via Our Site (or to use any services which we may from time to time provide on our site) you will be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14.
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. When making a Subject Access Request you should tell us everything we need to know to respond to your request as quickly as possible.
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 28 days and, in any case, not more than 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.
14. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
All Cookies used by and on Our Site will be used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up or prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Further information about “strictly necessary” Cookies can be obtained by request using the contact details provided in Part 15. 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 Site 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.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable 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
For the attention of Kyriacos Kyriacou
Email: info@elesma.co.uk
Telephone: +44 (0)20 7499 1029
Postal Address: Elesma Ltd. First Floor, 202 Kensington Church Street, London, W8 4DP, United Kingdom
16. Changes to this Privacy Policy
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.
Any changes will be promptly posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
17. Terms & Conditions
Use of Our Site is governed by our Terms & Conditions and this Privacy & Cookies Policy has been incorporated into the said Terms & Conditions by reference. This Privacy & Cookies Policy should be read in conjunction with the said Terms and Conditions. Click here to view the Terms & Conditions.