ELGIN PRIVACY POLICY

USER PRIVACY AND DATA PROTECTION

User privacy and data protection are human rights

We have a duty of care to the people within our data

Data is a liability it should only be collected and processed when absolutely necessary

We loathe spam as much as you do!

We will never sell, rent or otherwise distribute or make public your personal information

RELEVANT LEGISLATION

Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

EU Data Protection Directive 1995 (DPD)

EU General Data Protection Regulation 2018 (GDPR)

Swiss Supervisory System VQF

This site aims to always comply with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact us for clarification.

 

PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT

This website collects and uses personal information for the following reasons:

Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.

 

Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor see below.

 

GA makes use of cookies, details of which can be found on Google’s developer guides.

 

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

Our blog

Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below.

 

Your comment and its associated personal data will remain on this site until we see fit to either  1) remove the comment or 2) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us here using the email address that you commented with.

 

If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.

 

NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

 

Contact forms and email links

Should you choose to contact us using the contact form on our “Contact us” page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined below. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.

 

Email newsletter

If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Benchmark who provide us with email marketing services. We consider Benchmark to be a third party data processor (see below).

Your email address will remain within Benchmark’s database for as long as we continue to use Benchmark’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

 

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

 

While your email address remains within the Benchmark database, you will receive periodic (approximately one per month) newsletter-style emails from us.

 

HOW WE STORE YOUR PERSONAL INFORMATION

As detailed above, if you submit a comment to a blog post published on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion, a limitation of the content management system that this website is built on. In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual if you decide to use your real name.

Pseudonymisation is a recent requirement of the GDPR that many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.

 

ABOUT THIS WEBSITE’S SERVER

This website is hosted by LFC Hosting within Canadian data centres.

Some of the data centre’s more notable security features are as follows:

The facility is staffed 24/7 and also features enhanced onsite and offsite network monitoring, diesel back-up generators, 100 tons of cooling capacity, dual-stage gas fire suppression, and new physical security and surveillance characteristics.

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

 

OUR THIRD PARTY DATA PROCESSORS

We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with legislation. All of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.

Google https://policies.google.com/privacy

Benchmark https://www.benchmarkemail.com/email-marketing/privacy-policy

 

DATA BREACHES

We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

 

DATA CONTROLLER

The data controller of this website is: Elgin Administration (CY) limited

Whose registered office is:

82 Griva Digeni  Avenue

Limassol, 3101

Cyprus

 

CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time inline with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.

You account containing your personal information or any of the Information is password protected. Only third parties that log on with your password can access your account.

Please remember that you play a valuable part in security as well. Your password to access the Site, which you select at registration, should never be shared with anyone and should be changed frequently. And, after you have finished using our Site, you should log off and exit your browser so no unauthorised persons can use our Site with your password or identification number name. Furthermore, if you provide any information to parties who operate Websites that are linked to or from our Site, different rules may apply to their collection, use or disclosure of your personal information. We encourage you to review these sites’ policies before revealing any sensitive or personal information.

Regardless of the precautions taken by you or by us, “perfect security” does not exist on the Internet. We cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.

Visitors’ Questions

If you have any questions or concerns regarding your privacy while using this Web site, please direct them to info@elgingroup.com.