Privacy Policy - March 2024

Who we are

We are Elastic CAFNP Manager Ltd, a company registered in England and Wales (company number 14980138) with registered office at 14a Forest Gate, Chippenham, Wiltshire, England, SN15 3RS ("Elastic CAFNP", "we", "us" or "our").

1. About this Privacy Policy

   We respect your privacy and are committed to protecting your personal data. Our privacy policy gives you information about how Elastic CAFNP collects and uses personal data through the use of our website, including any data you may provide us when you register with, sign up to our newsletter, become our customer or provide us with a service. We are committed to safeguarding the privacy of our customers, partners, suppliers and website users.

   Our website is only intended for persons over the age of consent and we do not knowingly collect data relating to children. Please do not use our website if you are under 18 unless your guardian has provided consent for you to do so.

   Data Protection Laws: Our privacy policy complies with the General Data Protection Regulation (EU 2016/679) (EU GDPR) as well as the retained EU law version of the EU GDPR (the UK GDPR") and the Data Protection Act 2018 (together the "Data Protection Laws") as at the above date of our privacy policy.

   Data Controller

   Elastic CAFNP is the data controller, as required under the Data Protection Laws in the UK, and in this role we are responsible for your personal data.

   We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to our privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (section 11), please contact our DPO using the information set out in the contact details section (section 10).

2. The personal data we collect about you

   Personal data 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:

   • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, gender, your company and job title.
   • Contact Data includes email address, telephone numbers and your postal address for billing, delivery and communications.
   • Financial Data includes bank account and payment card details.
   • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website.
   • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
   • Usage Data includes information about how you interact with and use our website or our products and services.
   • Communications Data includes your messages sent through our website, email messages and telephone conversations.
   • Marketing 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 which is not personal data as it does not directly (or indirectly) reveal your identity (the ‘anonymous data’ referred to above). For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

   We use different methods to collect data from and about you including through:

   • Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
     • use our website;
     • apply for and/or use our services;
     • request marketing to be sent to you;
     • give us feedback or contact us;
     • information you contribute to our community, including reviews; and
     • your replies to polls and surveys.
   • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns to monitor how you use our website and services. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.
   • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
   • Technical Data is collected from the following parties:
     • analytics providers such as Microsoft based outside the UK.
     • search information providers such as Google based outside the UK.
   • Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe based outside the UK.
   • Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How we use your personal data

   Legal basis

   The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

   • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
   • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
   • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
   • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter. You have the right to withdraw consent to marketing at any time by sending us an email asking us to stop emailing or contacting you.
   • Vital interests: In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests. For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.
   
   

   Purposes for which we will use your personal data

   We have set out below, in a table format , a description of all the ways we plan to use the various categories of 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.

   Purpose/Use	Type of data	Legal basis and retention period
   To register you as a new customer to sell products and services to you, including: (a) verify your identity when you buy our services; (b) provide you with our services; and (c) provide you with suggestions and advice on products, services and how to obtain the most benefit to your business.	(a) Identity (b) Contact	Performance of a contract with you. We will retain this data and continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
   To process and deliver your order including: (a) manage payments, fees and charges; and (b) collect and recover money owed to us.	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy; and (b) dealing with your requests, complaints and queries.	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(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 manage our relationship with you) We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(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) We will retain this data for for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(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 We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	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) We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	(a) Technical (b) Usage	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) We will retain this data for [state retention period].
   To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods, services or job opportunities that may be of interest to you based on your Profile Data.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications. We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.
   To carry out market research through your voluntary participation in surveys.		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services). We will retain this data for as long as is reasonably needed to maintain and expand our relationship with you and in order to comply with our legal and contractual obligations. OR to protect ourselves from and potential disputes.

   
   
5. Direct marketing

   During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Elastic CAFNP via Email.

   We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

   Third-party marketing

   We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

   Opting out of marketing

   You can ask to stop sending you marketing communications at any time by clicking on the relevant link in the marketing emails.

   If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions, checking that your contact details are correct.

6. Cookies

   For more detailed information on the cookies we use, the purposes for which we use them and how to change your cookie preferences, please see our Cookies Policy.

7. Disclosures of your personal data

   For the purposes set out in our privacy policy above we may share your personal data with the parties set out below:

   • Specific third parties such as:
     • Credit reference agencies: so far as it relates to clients who cancel payments to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
     • Service providers and business partners: we may share your personal data with businesses that provide services to us, or with business partners. As examples: we may pass your payment information to our payment service provider to take payments from you; or we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud.
     • Where you have given us explicit permission to do so, to selected third party associates whom we consider may provide products or services you would find useful.
   • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

   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.

8. International transfers

   We do not transfer your personal data outside the UK.

9. 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.

10. Data retention

    How long will you use my personal data for?

    Details of retention periods for different aspects of your personal data are set out in the table in section 4 above.

    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.

    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.

    In some circumstances you can ask us to delete your data: see section 11 below for further information.

    In some circumstances we will 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.

11. Your legal rights

    You have a number of rights under data protection laws in relation to your personal data.

    You have the right to:

    • Request access to your personal data (commonly known as a "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 correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request erasure of your personal data in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
    • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see section 5 for details of how to object to receiving direct marketing communications).
    • 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.
    • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
      • If you want us to establish the data's accuracy;
      • Where our use of the data is unlawful but you do not want us to erase it;
      • 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
      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    If you wish to exercise any of the rights set out above, please contact us using the contact details in section 12.

    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). However, 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.

    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.

    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.

12. Contact details

    If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPOin the following ways:

    • Email address: info@elasticmint.com
    • Postal address: 14a Forest Gate, Chippenham, Wiltshire, England, SN15 3RS

    When you contact us via any of the above methods, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business.

    We may keep personally identifiable information associated with your message, such as Identity Data, so as to be able to track our communications with you to provide a high-quality service.

13. Complaints

    You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.

14. Changes to the privacy policy and your duty to inform us of changes

    We keep our privacy policy under regular review. This version was last updated in March 2024.

    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, for example a new address or email address

15. Third-party links

    Our 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 policy of every website you visit.

16. Delivery of services using third party communications software

    With your consent, we may communicate using software provided by a third party such as Facebook (Whatsapp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

    Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules and regulations, including the UK GDPR.

    If you have any concerns about using a particular software for communication, please contact us using the contact details in section 12.