Privacy Policy

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‍Last updated January 24, 2022‍

This is the privacy notice of Elm Row Ltd (‘we’, ‘our’, ‘us’).

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data ’is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website and through our social media platforms, Facebook, Instagram, YouTube, Twitter and LinkedIn.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

How we obtain personal data

The information we process about you includes information:

–     you have directly provided to us

–     that we gather from third party databases and service providers

–     as a result of monitoring how you use our website or our services

Types of personal data we collect directly

When you use our website, our services or buy from us, for example, when you submit a contact form of sign up to our newsletter, we ask you to provide personal data. This can be categorised into the following groups:

–     personal identifiers, such as your first and last names, your title and your date of birth

–     contact information, such as your email address for communication

–     records of communication between us including messages sent through our website, email messages and telephone conversations

–     marketing preferences that tell us what types of marketing you would like to receive

Types of personal data we collect from your use of our services

By using our website and our services, we process:

–     information you contribute to our community, including comments

–     your replies to polls and surveys

–     technical information about the hardware and the software you use to access our website and use our services, including yourInternet Protocol (IP) address, your browser type and version and your device’s operating system

–     usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages

–     your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us using the contact format www.elmrow.co.uk/contact. However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

‍Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

–     whether the same objective could be achieved through other means

–     whether processing (or not processing) might cause you harm

–     whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

–     improving our services

–     record-keeping for the proper and necessary administration of our business

–     responding to unsolicited communication from you to which we believe you would expect a response

–     preventing fraudulent use of our services

–     exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property

–     insuring against or obtaining professional advice that is required to manage business risk

–     protecting your interests where we believe we have a duty to do so

Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation. This may include your personal data.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website.

Information you provide

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

For example, when you leave a comment on our website, we reasonably assume that you consent for the message to be seen by others. We may include your username with your message, and your message may contain information that is personal data. In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared. We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal data that you have posted. You can make a request by contacting us using the contact form at www.elmrow.co.uk/contact

Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Information obtained from third parties

Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.

‍Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date. They can provide core functionality such as security, network management, and accessibility; record how you interact with the website so that we can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

–     to track how you use our website

–     to record whether you have seen specific messages we display on our website

–     to keep you signed in to our website

–     to record your answers to surveys and questionnaires on our site while you complete them

–     to record the conversation thread during a live chat with our support team

Personal identifiers from your browsing activity

Requests by your web browser to our servers for webpages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Re-marketing

Re-marketing involves placing a tracking technology such as a cookie to track which pages you visit and to serve you relevant adverts for our services when you visit other websites.

We may use a third-party advertising service to provide us with re-marketing services from time to time. We do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

Encryption of data sent between us

We use Secure Sockets Layer (SSL)certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

Data may be processed outside the UK

Our websites are hosted in the United Kingdom.

We may also use outsourced services in countries outside the UK from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the UK.

Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website. To obtain a copy of any information that is not provided on our website you should contact us to make that request.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request. This may limit the service we can provide to you.

We are not obliged by law to delete your personal data or to stop processing it solely because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Complaints

If you are not happy with our privacy policy, or if you have any complaint, then you should contact us in the first instance.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with theInformation Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

–     to provide you with the services you have requested

–     to comply with other law, including for the period demanded by our tax authorities

–     to support a claim or defence in court

Compliance with the law

Our privacy policy complies with the law in theUnited Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’)accordingly incorporating the EU General Data Protection Regulation (‘GDPR’)and the Privacy and Electronic Communications Regulations (‘PECR’).

Review of this privacy policy

We shall update this privacy notice from time to time as necessary.