Our Privacy Policy JBJ respects your privacy and is committed to protecting your personal |
data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 1. Important information and who we are 2. The data we collect about you 5. Disclosures of your personal data 6. International transfers |
9. Your legal rights 10. Glossary |
1. Important information and who we are
Purpose of this privacy notice This privacy notice aims to give you information on how Ellison collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our |
newsletter, sign up for our conferences, purchase of services, participate in surveys, or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children. |
Controller Ellison is the controller and responsible for your personal data (collectively referred to as Ellison, “we”, “us” or “our” in this privacy notice). Our full details are: |
Full name of legal entity: Ellison Marketing Ltd |
LL13 7YP |
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes |
This version was last updated on 1st January 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. |
When you leave our website, we encourage you to read the privacy notice of every website you visit. |
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data
• Identity Data includes first name, maiden name, last name, username or
where the identity has been removed (anonymous data). |
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: |
similar identifier, marital status, title, date of birth and gender.
|
|
products and services. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. |
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from
your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in
accordance with this privacy notice. |
includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. |
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o apply for our services;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey; or o give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites
o Technical Data from the following parties:
o Contact, Financial and Transaction Data from providers of
employing our cookies. Please see our cookie policy for further details. • Third parties or publicly available sources. We may receive personal
data about you from various third parties as set out below
▪ analytics providers such as Google based outside the EU; ▪ advertising networks |
▪ searchinformationproviders |
technical, payment and delivery services |
o Identity and Contact Data from data brokers or aggregators o Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU. |
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to
have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data |
Below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact if you need details about the specific legal ground we are relying on to process your personal data. |
Purpose/Activity
To register you as a new customer
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us Type of data
(a) Identity
(b) Contact
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest Performance of a contract with you
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
Purpose/Activity
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity
To enable you to partake in a prize draw, competition or complete a survey
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Purpose/Activity
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Purpose/Activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Purpose/Activity
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Purpose/Activity
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may |
be relevant for you (we call this marketing). Third-party marketing We will get your express opt-in consent before we share your personal data with any company outside Ellison for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at |
any time by contacting us. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please |
note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy. |
Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. |
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. |
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes outlined above.
• Internal Third Parties as set out in the Glossary. |
|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions. |
6. International transfers
We share your personal data within Ellison. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
data outside the EEA. |
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented |
7. Data security We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third |
parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. |
8. Data retention
We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Request |
erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. |
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us. No
fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. |
We may also contact you to ask you for further information in relation to your request to speed up our response. |
have made a number of requests. In this case, we will notify you and keep you updated. |
10. Glossary
LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your |
rights before we process your personal data for our legitimate interests. We do not use your personal data 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. |
data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES Internal Third Parties External Third Parties |
• Service providers acting as processors based who provide IT and system
administration services. |
lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. |
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to: |
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing |
(see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You |
also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. |
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our |
use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right |
only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. |