1. Introduction
- We are committed to safeguarding the privacy of our website visitors and service users.
- 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.
- By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
- 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
- In this Section 2 we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
- 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
- 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.
3. Providing your personal data to others
- 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.
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for:
- Obtaining or maintaining insurance coverage
- Managing risks
- Obtaining professional advice
- The establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
- In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject.
- We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims.
4. Retaining and deleting personal data
- 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.
- We shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
- All emails containing personal data must be encrypted using end-to-end encryption.
- All emails containing personal data must be marked “confidential”.
- Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances.
- Personal data contained in the body of an email should be copied and stored securely; the email itself should be deleted.
- 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.
- All personal data to be transferred physically shall be transferred in a suitable container marked “confidential”.
- We shall ensure that the following measures are taken with respect to the storage of personal data:
- All electronic copies of personal data should be stored securely using passwords and end-to-end encryption.
- All hardcopies of personal data should be stored securely in a locked box, drawer, cabinet, or similar.
- All personal data stored electronically should be backed up regularly with backups stored offsite.
- No personal data should be stored on any mobile device without formal written approval.
- No personal data should be transferred to any device personally belonging to an employee.
- Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.
- All reasonable steps will be taken to erase or otherwise dispose of it without delay.
- When any personal data is to be erased or otherwise disposed of, it should be securely deleted and disposed of.
- Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation.
5. Data Security – IT Security
- We shall ensure that the following measures are taken with respect to IT and information security:
- All passwords used to protect personal data should be changed regularly.
- Passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.
- Under no circumstances should any passwords be written down or shared between any employees.
- All software shall be kept up-to-date.
- No software may be installed on any Company-owned computer without prior approval.
6. Organisational Measures
- We shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- All employees shall be made fully aware of their responsibilities under the GDPR and this Policy.
- Only employees that need access to personal data shall have access.
- All employees handling personal data will be appropriately trained and supervised.
- Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed.
- All personal data held by the Company shall be reviewed periodically.
- All employees handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract.
- Where any agent, contractor, or other party fails in their obligations under this Policy, that party shall indemnify and hold harmless the Company.
7. Amendments
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
- In this Section 8, we have summarised the rights that you have under data protection law.
- Your principal rights under data protection law are:
- The right to access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object to processing
- The right to data portability
- The right to complain to a supervisory authority
- The right to withdraw consent
- You have the right to confirmation as to whether or not we process your personal data.
- You have the right to have any inaccurate personal data about you rectified.
- In some circumstances, you have the right to the erasure of your personal data without undue delay.
- You have the right to restrict the processing of your personal data in certain circumstances.
- You have the right to object to our processing of your personal data on grounds relating to your particular situation.
- You have the right to object to our processing of your personal data for direct marketing purposes.
- You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint.
- You have the right to withdraw consent at any time.
- You may exercise any of your rights in relation to your personal data by written notice to us.
9. About cookies
- A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser.
- Cookies may be either “persistent” cookies or “session” cookies.
- Cookies do not typically contain any information that personally identifies a user.
10. Cookies that we use
- We use cookies for the following purposes:
- Authentication – to identify you when you visit our website and as you navigate our website.
- Security – as an element of the security measures used to protect user accounts.
- Advertising – to help us display advertisements that will be relevant to you.
- Analysis – to help us analyse the use and performance of our website and services.
- Cookie consent – to store your preferences in relation to the use of cookies.
11. Cookies used by our service providers
- Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
- We use Google Analytics to analyse the use of our website.
- Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
12. Managing cookies
- 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 obtain up-to-date information about blocking and deleting cookies via these links:
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
13. Our details
- This website is owned and operated by Ellis Digital Media Limited.
- We are registered in England and Wales under registration number 09605720.
- Our registered office is at The Tile Kiln, Tilehouse Farm Offices, East Shalford Lane, Guildford, GU48AE
- Our principal place of business is at the same address.
- You can contact us:
- By post, to the postal address given above;
- Using our website contact form;
- By telephone, on the contact number published on our website;
- By email, using the email address published on our website