This website is operated by Elementary Digital Limited (“Elementary”, “us”, “we”, “our”). We are a controller for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679. We are registered with the Information Commissioners Office (registration number ZA100405).

We are committed to protecting your privacy and personal data. When you use our website or any of our services, we will collect a minimal amount of data about you, only process it where required and only store it for as long as is necessary. We’ve rewritten our privacy policy in plain English to be clear and transparent about how we collect and use your data.

This privacy policy applies to this website and all of the products and services offered by Elementary and affiliated companies.

Personal information which we collect

We collect personal information about you (and others if their personal information is provided by you) when you:

• make or manage an enquiry through our website;
• contact us or speak to one of our representatives via any forms on our website, by telephone, email or any other method;
• post material to our website and / or social media page;
• take part in any customer services or surveys related to our services;
• enter into any agreement with us or use our services;
• and / or use our website and customer applications in any other way.

The personal information collected in the above manner may include the following about you (and others if their personal information is provided by you):

• full name;
• postal address;
• email address;
• telephone number;
• payment details;
• geo-location;
• machine identifiers (such as IP addresses);
• dispute resolution information;
• image data;
• behavioural data (tags and cookies – see Cookies and Tracking section below);
• third party service identities (such as a Skype or Trello ID or social network identities);
• communications history (such as email communications or Slack chats);
• login credentials.

How we use your information

In order to take the necessary steps in preparation of, or to fulfill our obligations under, a contract:

• Services and payments: provide communications about our products and services being provided to you (and others if their personal information is provided by you);
• Account updates: send details of new, amended or cancelled services provided to you;
• Billing: to send you invoices and related communications regarding accounting matters for the services we provide to you;
• Customer service communications: provide you with requested information or correspondence, in response from us to an enquiry made by you;
• Update our records: to ensure that the data we store about you is still valid and up to date.

With your consent:

• Marketing communications: create a profile about you for marketing purposes to tailor our communications to you. We may use automated processes to do this;
• Maintain records indicating your consent to status: to ensure we accurately reflect your wishes when communicating to you.

In our legitimate interest improve our services

• Market research: to contact you to ask about the experience using our services as part of a continual programme of customer service improvement. We may use third parties to provide such market research communications to you on our behalf;
• Website customisation: to customise our website and its content to your particular preferences in accordance with the Cookies and Tracking section below;
• Customer support: monitor communications and to help train staff in relation to our customer support function;
• Product and service improvement: to improve our product and services;
• Service analysis: to conduct research, statistical analysis and behavioural analysis. This may include providing aggregate statistical information relating to customers, sales, traffic patterns and related site information to reputable third parties.

In order to meet our legal obligations:

• Taxation: to ensure we meet our tax and other regulatory obligations.

Sharing your information

We will never share your personal information to any third parties except where it is necessary for us to provide our services to and on behalf of you.

The third party services we use include:

Service	Purpose
Trello	for project management and support requests	Privacy policy
WP Engine	for hosting services	Privacy policy
Amazon Web Sercices	for hosting services	Privacy policy
UK Fast	for hosting services	Privacy policy
Namecheap	for SSL certificates	Privacy policy
Heart internet	for domain registration and DNS control	Privacy policy
Mandrill	for sending transactional and notification email	Privacy policy
1Password	for storage of secure information, including login credentials and security keys	Privacy policy
Slack	for communications	Privacy policy
Skype	for communications	Privacy policy
Google Apps (including Mail, Calendar, Hangouts and Drive)	for communications, storage of assets and agreements, documents and scheduled meetings	Privacy policy
We Transfer	for transfer of assets or large files
Bitbucket	for storage and version control of a website or application’s codebase	Privacy policy
Xero	for invoicing	Privacy policy
Moneypenny	for call routing and messaging	Privacy policy

We will only share your information when it is absolutely necessary.

We may also provide aggregate statistics about our customers, sales, traffic patterns and related site information to reputable third parties in order to better understand our services, website and overall customer satisfaction which may include personally identifying information.

In the event Elementary or any of its affiliated companies is acquired by a third party, in which case personal data held by Elementary about its clients will be transferred as part of the assets of the firm.

We may be in a position whereby we have a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to apply our terms of use as stated in our agreement. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

How long we will keep your personal information

When you make an enquiry you will consent to share information with us and advice will be provided. Your personal data and advice given will be held for one year.

When you become a client of Elementary your data and project history will also be held for one year (from the date your contract is deemed fulfilled).

When you consent to marketing communications, your data will be held for three years from the date that you last consented.

We will remove your data from our systems at the end of the applicable data retention periods, unless we are required by current or future law to retain your personal information for a longer period.

Marketing

We may periodically send marketing material to you about our products and services or other information which we think you may find interesting based on the profile we have created about you to the email addresses and phone numbers which you have provided.

We will only send you marketing material if we have your prior consent or if you are currently a member of a client Elementary. We gain your consent by asking for your positive confirmation (example: by providing a tick or inserting your contact details in the relevant input fields on a form on our website).

You can opt out at any time from our marketing materials.

We may use your information to create a profile about you in order to tailor, by automated means, our communication and marketing to you. You can object to such profiling (please see ‘The right to object to automated decision making / profiling’ below).

From time to time, we may also use your information to contact you for research purposes and / or to ask about your experience using our services as part of a continual programme of customer service improvement. We may contact you by email, telephone, text, social media and / or mail. We may also use the information to customise the website according to your interests.

Securing your information

Elementary has policies and procedures in place to make sure that only authorised personnel can access your information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have proportionate and reasonable security measures in place.

There may be occasion for such activities as payment transactions or general communications, for example, when data that we collect may be transferred to a destination outside the European Economic Area (“EEA”). In submitting your personal data for this purpose, you agree to this transfer, storing or processing. We will however take all steps that are reasonably necessary to ensure that your data is stored in accordance with this privacy policy and securely.

While we take commercially reasonable measures to ensure the safety and security of your data, due to the inherent risks with the Internet, we are unable to warranty the absolute security of your data when using our services.

Your rights

• The right to be informed: you have the right to be informed about the data we collect and store about you and how we use it. This privacy policy it set out to inform you.
• The right of access: you can contact us to request details about the information we hold about you, why we have it, who has access to it and where we got the information.
• The right to rectification: If any data we hold about you is out of date or incorrect, let us know and we will update it
• The right to erasure: you have a right to request we delete any data we hold about you. When you request that we delete your data we will contact you to confirm that it has been deleted or advising of any legal reason we cannot delete your data.
• The right to restrict processing: You have the right to request that Elementary stops processing your data. When you request this, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.
• The right to data portability: You have the right to request that we transfer your data to another controller. When you request this, we will make reasonable attempts to do so.
• The right to object: you have the right to object to the storage and usage of your data
• Rights in relation to automated decision making and profiling: You have the right to request that we stop profiling you in relation to our direct marketing practice. You can inform us and we will deal with your request accordingly.

We will respond to all requests as soon as is feasible, without undue delay and within 30 days from receiving your request.

Use of cookies and tracking

Our websites use cookies. A cookie is a small text file that can be stored by your browser on the device you use to access internet and allows the browser to pass small amounts of information about user behaviour on the given website to a web server. Tags are pieces of code that exist on web pages and collect information about usage of the web pages.

We use our own cookies and tags as well as those from third parties to enable the smooth operation of our websites and to personalise your experience. We also use cookies/tags to monitor visits to our website and continuously look for places to improve your website experience. Our marketing partners also use cookies and tags to monitor the performance of our advertising and to serve appropriate Elementary advertisements to you on other websites. We will never share any personal information about you with these third parties and the cookies and tags used maintain your anonymity.

You can block or reject cookies using your browser’s preferences. For more information about cookies, and how to manage or delete them www.allaboutcookies.org.

Links to other websites

There may be pages on our websites which include links to other websites which are owned and operated by third parties which do not operate this privacy statement. When you link to other websites, this privacy statement and our privacy practices no longer apply. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information.

Changes to this Privacy Policy

We may change this policy from time to time. You should check this policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.

Questions

If you have any further questions or would like information regarding the data we hold about you, you can contact us or email our data protection officer dpo@elementarydigital.co.uk