Privacy & Cookie Policy
Elite Virtual Assistant Limited
1. Introduction
This Privacy and Cookie Policy (“Policy”) will inform you as to how we collect and look after your personal data when you visit our website (regardless of where you visit it from) or when you become a client of ours and when you receive virtual assistant service from us and how the law protects you. Please READ this Policy carefully. If you do not agree with the provisions of this Policy, please do not use our website and our services. By accessing or using our website or services, you agree to the terms of this Policy.
2. Who We Are/Controller and Processor Activities
Elite Virtual Assistant Limited (collectively referred to as “we”, “us” or “our” in this Policy) will be either the data controller or the data processor, depending on what activities we are carrying out. We will be regarded as the data controller when we are directly collecting personal data from you, which is about you. When we are dealing with any personal data about your clients, which you have shared with us, we will be considered as a data processor. In those instances, the data processing terms set out in our Virtual Assistant Business Terms will apply. This Policy covers our use of data when collected by us in our data controller capacity, so the data about you as an individual and our client.
If you have any questions about this Policy including any requests to exercise your legal rights, or our privacy practices, please contact us in the following ways:
Full Entity Name: Elite Virtual Assistant Limited
Email: mel@elitevaltd.co.uk
Address: Elite Virtual Assistant Limited, 96 Broad Oaks Road, Solihull, B91 1HZ
Telephone: 07754 037 012
3. Changes to the Privacy & Cookie Policy and Your Duty to Inform us of Changes
We keep our Policy under regular review. It is important that the personal data we hold about you is accurate and current so please keep us informed if your personal data changes during your relationship with us.
4. 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, please take the time to read the privacy policy of every website you visit.
5. Use of Website by Children
Our website is not intended for children under 18 years of age. We do not sell products or provide services for purchase by children, nor do we market to children. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website unless you have consent from a parent or guardian. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information.
6. What Information is being Collected
We will collect the personal data that you provide to us. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data 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 as follows:
We do not monitor your use of the internet but we do use cookie technology to monitor your use of our website. This information is not stored alongside your personal data and will only be used on an anonymous, aggregated basis.
7. How We Obtain Data
We use different methods to collect data from and about you. Whenever you interact with us, we collect data. Sometimes you provide us with data, sometimes data about you is collected automatically. Here is how and when we do this:
We may also receive your personal data from the following third parties:
We may receive technical data from analytics providers, such as Google based outside the UK.
8. How we use Your Personal Data
We will only use your personal data when the law allows us to, usually in the following circumstances:
9. Purpose for which we will use Your Personal Data
Please find below a description of the ways we plan to use your personal data and the legal grounds on which we rely to do so and explained what our legitimate interests are, where appropriate.
Please 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. If you need details about the specific legal ground on which we are relying to process your personal data, where more than one ground has been set out below, please contact us.
Purpose/Activity - To respond to your enquiry about our services.
Type of data - Identity, Contact, Usage, Profile
Lawful basis for processing including basis of legitimate interest - Performance of a contract with you.
Necessary for our legitimate interest (to develop our products/services and grow our business).
Purpose/Activity - To share free resources with you or to make suggestions and recommendations to you about goods or services that may be of interest to you.
Type of data - Identity, Contact, Technical, Usage, Profile, Marketing and Communications
Lawful basis for processing including basis of legitimate interest - To pursue our legitimate interest (to develop our products/services and to grow our business).
Purpose/Activity - To register you as a new client and/or provide services to you.
Type of data - Identity and Contact
Lawful basis for processing including basis of legitimate interest - Performance of a contract with you.
Consent.
Purpose/Activity - To process and deliver a contract including (a) manage payments, fees and charges and (b) collect and recover money owed to us.
Type of data - Identity, Contact, Financial, Transaction, Marketing and Communications
Performance of a contract with you.
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services and 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 and (b) Asking you to leave a review or take a survey.
Type of data - Identity, Contact, Profile, Marketing and Communications
Lawful basis for processing including basis of legitimate interest - Necessary to comply with a legal obligation.
Purpose/Activity - To enable you to partake in a prize draw, competition or complete a survey.
Type of data - Identity, Contact, Profile, Usage and Marketing and Communications
Lawful basis for processing including basis of legitimate interest - Performance of a contract with you.
Necessary for our legitimate interests (to study how clients 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 - Identity, Contact and Technical
Lawful basis for processing including basis of legitimate interest - 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 re-organisation or group restructuring exercise). 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 - Identity, Contact, Profile, Usage, Marketing and Communications and Technical
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to study how clients 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, client relationships and experiences.
Type of data - Technical and Usage
Lawful basis for processing including basis of legitimate interest - Necessary for our legitimate interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
10. 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 on mel@elitevaltd.co.uk. 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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. Cookies
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
12. Data Storage
We will not transfer your data outside the UK or European Economic Area (EEA). Some of our external third parties may use servers outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA. This applies to standard services with reputable suppliers such as Google and Dropbox. Whenever your personal data is transferred out of the EEA, these third parties will ensure a similar degree of protection is afforded to it in compliance with EU data protection laws.
13. 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.
14. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data, please see ”Your Legal Rights” below for further information.
15. Who we may Share your Personal Data with
We may share your personal data with selected third parties exclusively to provide services to you, for example:
Third parties will not have access to any of your client’s confidential information. Any such information will be kept 100% confidential and not be shared with any third party. 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.
16. Your Legal Rights
You have the right to:
If you wish to find out more about any of these rights please visit the ICO website or exercise any of the rights set out above, please contact us via email at mel@elitevaltd.co.uk.
17. No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
18. What we may need from you
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.
19. Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
20. Complaints
You have the right to complain about how we treat your personal data to the Information Commissioner’s Office (the “ICO”). We would, however, appreciate the chance to resolve any concerns before you approach the ICO, so please contact us first at mel@elitevaltd.co.uk. The ICO can be contacted at https://ico.org.uk/global/contact-us/email.