Privacy & Cookies Policy2018-05-18T11:40:56+00:00

Privacy & Cookies Policy

1. Introduction

1.1  We are committed to safeguarding the privacy of our website visitors and service users.

1.2  This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3  By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4  In this policy, “we”, “us”, “our” and “Company” refer to Ellis Digital Media Limited. For more information about us, see Section 13.

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 data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website 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 website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3  We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back- ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4  We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, address and contact details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5  We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6  We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.7  We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.8  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.9  We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. 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 website and business and communications with users.

2.10  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.

2.11 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 policy.

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  In addition to the specific disclosures of personal data set out in this Section 4, 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. Retaining and deleting personal data

4.1  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.

4.2  We shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

  1. (a)  All emails containing personal data must be encrypted using end to end encryption.
  2. (b)  All emails containing personal data must be marked “confidential”;
  3. (c)  Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
  4. (d)  Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted.
  1. (e)  Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using an agreed alternative delivery service; and
  2. (f)  All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

4.3  We shall ensure that the following measures are taken with respect to the storage of personal data:

  1. (a)  All electronic copies of personal data should be stored securely using passwords and end to end data encryption;
  2. (b)  All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
  3. (c)  All personal data stored electronically should be backed up regularly with backups stored offsite. All backups should be encrypted using end to end encryption;
  4. (d)  No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Director and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
  5. (e)  No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
  1. 4.4  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. All reasonable steps will be taken to erase or otherwise dispose of it without delay.
  2. 4.5  When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

4.6  Notwithstanding the other provisions of this Section 6, 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.

5. Data Security – IT Security

5.1  We shall ensure that the following measures are taken with respect to IT and information security:

5.2  All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords.;

5.3  Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

5.4  All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and

5.5  No software may be installed on any Company-owned computer or device without the prior approval of the Director.

6. Organisational Measures

6.1  We shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

6.2  All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;

6.3  Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

6.4  All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

6.5  All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

6.6  All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

6.7  Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

6.8  All personal data held by the Company shall be reviewed periodically.

6.9  The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

6.10  All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

6.11  All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

6.12  Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

7. Amendments

7.1  We may update this policy from time to time by publishing a new version on our website.

7.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

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:

  1. (a)  the right to access;
  2. (b)  the right to rectification;
  3. (c)  the right to erasure;
  1. (d)  the right to restrict processing;
  2. (e)  the right to object to processing;
  3. (f)  the right to data portability;
  4. (g)  the right to complain to a supervisory authority; and
  5. (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. You can access your personal data by contacting us directly.

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:

  1. (a)  consent; or
  2. (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.

9. About cookies

9.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a)  authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: identify cookies);

(b)  security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: identify cookies);

(c)  advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: identify cookies);

(d)  analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: identify cookies); and

(e)  cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: identify cookies).

11. Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: identify cookies.

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)  https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)  http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)  https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)  https://support.apple.com/kb/PH21411 (Safari); and

(f)  https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1  This website is owned and operated by Ellis Digital Media Limited.

13.2  We are registered in England and Wales under registration number 09605720 and our registered office is at Office 19, 15 Church Street, Weybridge, Surrey, KT13 8NA.

13.3  Our principal place of business is at Office 19, 15 Church Street, Weybridge, Surrey, KT13 8NA.

13.4  You can contact us:

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

(b)  using our website contact form;

(c)  by telephone, on the contact number published on our website from time to time; or

(d)  by email, using the email address published on our website from time to time.