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This notice is for those supplying goods and services to Elephant Creative

1. Introduction

1.1 We are committed to safeguarding the privacy of all individuals whose personal data we store and process; in this notice we explain how we will handle your personal data.

1.2 This notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 In this notice, “we”, “us” and “our” refer to Elephant Creative Solutions Limited.

 

2. How we use your personal data

2.1 In this section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process your business contact information and related personal details (“contact data”). The contact information may include your name, details of your job or role, your business email address, your business postal address and your business telephone number. The source of the contact information will be you or your employer. The contact data may be processed for the purposes of communicating with you and your employer, and keeping records relating to our relationship with your employer and the services that your employer provides to us. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.

2.3 We may process your personal data that is contained in or associated with any deliverables that you produce and provide to us, or that is contained in or associated with any deliverables produced and provided to us by your employer or any relevant third party in connection with the work that your employer performs for us (“deliverables data”). The source of the service data is you, your employer or the relevant third party. The deliverables data may be processed for the purpose of operating our business. The legal basis for this processing is our legitimate interests, namely enjoying the benefits of services your employer provides to us and the proper administration of our business.

2.4 We may process your personal data relating to the services that your employer provides to us, including data in contracts between us and your employer, data concerning the nature of the services and data concerning the time and manner of the performance of the services (“services data”). The source of the services data is you, your employer or our own personnel. The services data may be processed for the purposes of monitoring your performance, managing our relationship with you and your employer, providing our own services to customers, ensuring the security of our services and keeping records of the services your employer provides. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.

2.5 We may process data about your use of our software and IT systems (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system and navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the software and IT systems. The legal basis for this processing is our legitimate interests, namely monitoring the use of our software and IT systems.

2.6 We may process information contained in or relating to any communication that you send to us or that we send to you (“correspondence data”). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with relevant persons.

2.7 We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8 We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.9 In addition to the specific purposes for which we may process your personal data set out in this section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

 

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the proper administration of our business and communications with relevant persons.

3.4 In addition to the specific disclosures of personal data set out in this section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

4. International transfers of your personal data

4.1 In this section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 Your personal data will be stored on servers owned by Zoho Corporation, in USA. Zoho Corporation participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework, with respect to transfer of data to the U.S. Zoho Corporation has also demonstrated its commitment to data privacy and protection by meeting the industry standards for ISO 27001 and SOC 2 Type 2.

 

5. Retaining and deleting personal data

5.1 This section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) personal data will be retained for a minimum period of five years following 25th May 2018, and for a maximum period of 10 years following 25th May 2018.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of personal data will be determined based on the rules set out in section 4.3.

5.5 Notwithstanding the other provisions of this section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

6.3 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.4 You should ensure that your passwords used to access our software and IT systems are not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the passwords confidential and we will not ask you for your passwords (except when you log in to our software and IT systems).

 

7. Amendments

7.1 We we publish changes to this notice on our website at www.elephantcreative.co.uk.

7.2 We will notify you of any changes to this notice which may affect you by email or post.

 

8. Your rights

8.1 In this section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section 8.

 

9. Our details

9.1 Our full legal name is Elephant Creative Solutions Limited.

9.2 We are registered in England and Wales under registration number 7261689, and our registered office is at The Office, The Bungalow, High Street, Northleach GL543EU.

9.3 Our principal place of business is at The Office, The Bungalow, High Street, Northleach GL543EU.

9.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form at www.elephantcreative.co.uk;

(c) by telephone, on 01451 861804; or

(d) by email, to contact@elephantcreative.co.uk.