Version 1.0, Effective 25th May 2018
We have tried to keep this simple, but if you’re not familiar with terms like “cookies”, “IP addresses” or “API”, then feel free to email us at firstname.lastname@example.org.
Your privacy is really important to us, so whether you’re new to Digital Elite or a long-time customer, please take the time to get to know our practices
Our goal is to always to be relevant, be helpful, be transparent. We will never be spammy, interruptive or aggressive. We have strived to ensure our easily accessible and written in clear and plain language, there is no complex legalese.
There is a lot of information below, however to summarise a few key points:
- We don't send spam
- We will never sell your personal information to any third party
- We will never sell advertising space or run adverts on our website
- We don't automatically add people to nurture lists and email them forever more
- We don't follow you around the web with never-ending retargeting adverts
- Should you opt-in to receive information from us, you can opt-out any time
Information We Store
The personal information we collect from you will vary depending on which products and/or services you engage us to deliver, however information is typically limited to the following:
- Identity information, such as your first name, last name, username or similar identifier and title
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username and password (if you register for an online login) as well as links to your social profiles
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond and communicate with us including technical notices, updates, security alerts and support or administrative messages;
- Transaction information, such as details about purchases you or your company have made with us
- Usage information, such as information about how you use the Service and interact with us;
- Marketing information, to better understand your needs and interests such as your preferences for receiving marketing communications
We do not collect, store or process what GDPR describes as "sensitive personal data" such as personal financial account information, social security numbers, passport numbers, driving license numbers, racial or ethnic origin, physical or mental health information, other employment, financial, health or other personal identifiers.
How We Use Your Information
We only use your personal information as permitted by law. We need your consent to hold your contact information and provide a reason (“lawful basis”) for holding this information.
We store your information for the following reasons:
- To send you newsletters and other information you've opted in to ("consent")
- To send you invoices and bills as a customer ("performance of a contract")
- To send you other information relating to our business ("legitimate interest")
- To provide the service; Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. To fulfil our contractual obligations in providing consulting services to you
- To communicate with youTo create anonymous data for analytics; These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- For compliance, fraud prevention and safety; These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- To comply with law; Processing is necessary to comply with our legal obligations
- With your consent; Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at email@example.com.
When We May Use Your Information
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Digital Elite. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
If you request information from us, register for our services, or participate in our surveys, promotions or events, we may send you Digital Elite-related marketing communications if permitted by law but will provide you with the ability to opt out at the bottom of each such email. You may continue to receive service-related and other non-marketing emails.
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information or you opt into third party marketing communications.
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
To exercise any of these rights, please contact us at firstname.lastname@example.org or at our postal address provided on our website. We will respond to your request to change, correct, or delete your information within a reasonable timeframe (less than 30 days) and notify you of the action we have taken. We may request specific information from you to help us confirm your identity and process your request.
Third Party Processors
We use the following third party data processors that may have access to and/or process data on our behalf:
- Our Vetted Team
- Google Analytics
- Active Campaign
We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
Consent, as described in Article 4.11 of the GDPR is:
- A “clear affirmative action” taken by the data subject (user)
- Freely given by the data subject
- Specific, informed, and unambiguous
- Documented in detail by the data controller (the company that determines how the data will be processed)
- Easily withdrawn
We will never force you into consent, or try to hide that you are consenting to processing of their personal data. We consider entering your name and email on our site, and pressing the submit button, as "a clear affirmative act". Where we use forms of newsletter or ongoing sign-ups, a double opt-in (also known as a confirmation opt-in) flow will be used.
You are free to explore the Websites without providing any Personal Information about yourself.
We store anonymised information about the pages that users visit and the features that they use, and the actions that they take while using our website.
On occasion may use additional tools that provide Heatmaps and Recordings of visitors on our website to better understand visitor behaviour, however these tools have no means or tracking an individual visitor.
Google Analytics uses IP address information to provide geo-location information, however this information is never exposed in reports and, without the intervention of an internet service provider, we are completely unable to tie this information back to an individual.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We take information security very seriously, this includes us, our employees and any third party contractors. Please take time to review our Security Policy which includes further information on how we handle security across the company, including:
- 2Factor Authentication
- VPN Access
- Software Updates
We continue to work to strengthen our security controls.
Changes To Our Policy