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Privacy Policy

Privacy Policy

DATA PROTECTION

 

Introduction

Welcome to the privacy notice of Elite Hub Global Ltd.

At Elite Hub Global Ltd, we value your privacy and are dedicated to safeguarding your personal data. This privacy notice is designed to inform you about how we handle your personal data, your privacy rights, and the legal protections in place.

To enhance readability, this privacy notice is organized in a layered format. Please refer to the Glossary for definitions of specific terms. Note that this notice adheres to the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018.

 

  1. Important Information
  2. How Is Your Personal Data Collected
  3. The Data We Collect About You
  4. How We Use Your Personal Data
  5. Disclosures of Your Personal Data
  6. International Transfers
  7. Data Security
  8. Data Retention
  9. Your Legal Rights
  10. Glossary

 

  1. IMPORTANT INFORMATION 

Purpose of this Privacy Notice

This privacy notice is intended to inform you about how Elite Hub Global Ltd gathers and processes your personal data when you interact with our website (www.elitehubglobal.com) or utilize our services. This includes any information you provide when subscribing to our newsletter, making a purchase, or participating in competitions. Please note that our website is not designed for use by children.

It is essential to read this privacy notice in conjunction with any additional privacy notices or fair processing notices we may provide on specific occasions when collecting or processing your personal data. This comprehensive approach ensures you have a complete understanding of how and why we use your data. This privacy notice is complementary to other notices and is not intended to supersede them.

 

Controller

We operate as a ‘data controller,’ indicating our responsibility for determining how personal information about you is managed and utilized, with a commitment to providing clear explanations. Elite Hub Global Ltd assumes the role of the data controller for all information processed by our organization.

This privacy policy is applicable to a broad spectrum of individuals, including prospective, current, and former members of Elite Hub Global Ltd. This includes employees and representatives of our corporate members, individual and business contacts, prospects, referrers, those seeking information from us, as well as individuals providing services to us—whether as individuals or as employees or representatives of corporate service providers. Additionally, it encompasses third parties acting on behalf of our members.

 

Contact details:

Full name of legal entity: Elite Hub Global Ltd

Email address: contact@elitehubglobal.com

Postal address: 345a Flat 2 Cro 6rg Lower Addiscombe Road, London, United Kingdom, CR0 6RG

Telephone number: +34 613 097 238

You retain the right to file a complaint with the Information Commissioner’s Office (ICO), the authoritative body for data protection issues in the UK (www.ico.org.uk). However, we kindly request the opportunity to address and resolve your concerns before involving the ICO. In the initial instance, please reach out to us directly.

Maintaining the accuracy and currency of the personal data we hold about you is crucial. Kindly inform us promptly of any changes to your personal information during our relationship. Additionally, we commit to keeping you informed of any changes to our privacy policy.

 

Third-party links

Our website (www.elitehubglobal.com) might feature links to third-party websites, plug-ins, and applications. Clicking on these links or enabling such connections may enable third parties to collect or share data about you. It’s essential to note that we do not have control over these third-party websites and do not assume responsibility for their privacy statements. We strongly advise you to review the privacy notice of each website you visit when you navigate away from our site.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We employ various methods to collect data from and about you, including:

  1. Direct Interactions:

   – You may provide us with your Identity, Contact, and Financial Data through forms or communication via post, phone, email, or other means.

   – This includes instances when you:

     – Apply for our products or services.

     – Create an account on our website.

     – Subscribe to our services or publications.

     – Request marketing materials.

     – Enter a competition, promotion, or survey.

     – Provide feedback.

  1. Automated Technologies or Interactions:

   – As you engage with our website, we may automatically collect Technical Data related to your equipment, browsing actions, and patterns.

   – This involves the use of cookies, server logs, and similar technologies.

   – Further details can be found in our cookie policy.

  1. Third Parties or Publicly Available Sources:

   – We may receive personal data from various third parties and public sources, including:

   – Technical Data from analytics providers such as Google, situated outside the UK.

   – Identity and Contact Data from publicly available sources like Companies House and the Electoral Register, located within the UK.

 

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or information pertaining to an individual allowing for identification, excludes data where the identity has been removed, commonly known as anonymous data. We may collect, use, store, and transfer various types of personal data, grouped as follows:

 

  1. Identity Data:

   – First name, maiden name, last name, username or similar identifier.

   – Marital status, title, date of birth, and gender.

  1. Contact Data:

   – Billing address, delivery address, email address, and telephone numbers.

  1. Marketing and Communications Data:

   – Preferences regarding receiving marketing materials from us and third parties.

   – Communication preferences.

  1. Financial Data:

   – Bank account and payment card details.

  1. Transaction Data:

   – Details about payments to and from you.

   – Other information related to products and services you have purchased from us.

  1. Technical Data:

   – Internet protocol (IP) address, login data, browser type and version.

   – Time zone setting and location, browser plug-in types and versions.

   – Operating system and platform, and other technology on the devices used to interact with or access this website.

  1. Profile Data:

   – Membership identification number, purchases or orders made by you.

   – Your interests, preferences, feedback, and survey responses.

  1. Usage Data:

   – Information about how you use our website, products, and services.

 

In addition, we collect, use, and share Aggregated Data, such as statistical or demographic data, for various purposes. Aggregated Data is derived from personal data but is not considered personal data under the law, as it does not directly or indirectly reveal identity. For example, we may aggregate Usage Data to determine the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data in a way that can directly or indirectly identify you, we treat the combined data as personal data, used in accordance with this privacy notice.

Furthermore, we may collect Special Categories of Personal Data about you, encompassing 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.

In situations where we are legally obligated or have a contractual agreement with you to collect personal data, and you fail to provide the required information upon request, it may hinder our ability to fulfill the contract we have or are attempting to establish with you. For instance, this could impact our ability to provide you with certain services. In such cases, if the necessary personal data is not provided, we may need to cancel a product or service you have with us. We commit to informing you promptly if this becomes necessary at the time.

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only process your personal data in accordance with the law, and the most common circumstances under which we will use your personal data include:

  1. Performance of a Contract:

   – When it is necessary to fulfill the contract we are about to enter into or have entered into with you.

  1. Legitimate Interests:

   – When processing is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests.

  1. Legal or Regulatory Obligation:

   – When it is necessary to comply with a legal or regulatory obligation.

While processing your personal data, we generally do not rely on consent as a legal basis, except for situations involving third-party direct marketing communications sent to you via email or text message. You have the right to withdraw your consent for marketing at any time by contacting us.

 

Purposes for which we will use your personal data:

We have outlined below, in a tabular format, a description of all the ways we intend to use your personal data, along with the legal bases on which we rely for each purpose. We have also identified our legitimate interests where applicable. Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose. If you require details about the specific legal ground we are relying on for processing your personal data when more than one ground has been specified in the table below, please feel free to contact us.

Purpose/Activity

Type of data

Lawful basis/bases for processing including basis of legitimate interest

To register you as a new member or customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your requests and orders including:

(a) Fulfilment of requests placed by you or on your behalf

(b) Manage payments, fees and charges

(c) 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)

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

(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 to study how customers use our products/services)

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)

To administer and protect our business and this 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

To deliver relevant website content and 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)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(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)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We are dedicated to offering you choices regarding specific uses of your personal data, especially in the context of marketing and advertising.

 

Promotional offers from us

We may analyze your Identity, Contact, Technical, Usage, and Profile Data to understand your preferences and interests. This helps us determine relevant products, services, and offers for you, a practice referred to as marketing.

If you have sought information from us, placed a request, or made a purchase, or if you provided your details during a competition or promotion registration, you may receive marketing communications from us. This assumes you have not opted out of receiving such marketing communications.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Elite Hub Global Ltd of companies for marketing purposes.

 

Opting out

You have the option to request us or third parties to cease sending you marketing messages at any time by contacting us. However, please note that opting out of marketing messages does not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.

 

Change of purpose

We will strictly use your personal data for the purposes for which we initially collected it unless we reasonably determine that we need to use it for another reason, and that reason aligns with the original purpose. If you seek an explanation of how the processing for the new purpose aligns with the original purpose, please contact us.

In the event that we need to use your personal data for an unrelated purpose, we will notify you and provide an explanation of the legal basis that permits us to do so. It is important to note that we may process your personal data without your knowledge or consent in accordance with the aforementioned rules, as required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may need to share your personal data with the following parties for the purposes outlined in the table in paragraph 4 above:

– External Third Parties, as defined in the Glossary.

– Third parties to whom we may opt to sell, transfer, or merge parts of our business or assets. In the event of such a change to our business, the new owners may use your personal data in the same manner as outlined in this privacy notice.

We impose strict requirements on all third parties to uphold the security of your personal data and handle it in accordance with the law. Our third-party service providers are not permitted to use your personal data for their own purposes, and they are only authorized to process it for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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 United Kingdom laws and following International Data Transfer Agreement issued by the Information Commissioner’s Office (ICO).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

  1. DATA SECURITY

We have implemented suitable security measures to prevent your personal data from being unintentionally lost, accessed or used in an unauthorized manner, altered, or disclosed. Furthermore, access to your personal data is restricted to employees, agents, contractors, and other third parties who require the information for business purposes. These individuals will process your personal data solely based on our instructions and are bound by a duty of confidentiality.

 

Procedures have been established to address any suspected breaches of personal data, and we will promptly notify you and any relevant regulatory authority of a breach if it is legally required.

 

  1. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including meeting legal, accounting, or reporting requirements. The duration for which we keep your personal data is determined by factors such as the nature and sensitivity of the information, potential risks from unauthorized use or disclosure, the purposes of processing, and legal requirements.

By law, we are obligated to retain basic customer information (including Contact, Identity, Financial, and Transaction Data) for seven years after the customer relationship ceases for tax purposes. However, you have the right to request the deletion of your data in certain circumstances, as outlined in the “Request erasure” section below.

In some cases, we may anonymize your personal data for research or statistical purposes. Once anonymized, the data can no longer be associated with you, and we may use it indefinitely for these purposes without further notice.

 

  1. YOUR LEGAL RIGHTS

As an individual, you have specific rights under data protection laws regarding your personal data. Here is an overview of those rights:

  1. Request access to your personal data: You have the right to obtain confirmation of whether we are processing your personal data and, if so, access to that data along with specific information.
  2. Request correction of your personal data: If you believe that any personal data we hold about you is inaccurate or incomplete, you have the right to request correction.
  3. Request erasure of your personal data: You can request the deletion or removal of personal data when there is no compelling reason for us to continue processing it.
  4. Object to processing of your personal data: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
  5. 5. Request restriction of processing your personal data: You can ask us to suspend the processing of your personal data in certain scenarios, for example, if you want us to establish its accuracy or the reason for processing it.
  6. Request transfer of your personal data: You have the right to request the transfer of your personal data to you or to a third party. We will provide it in a structured, commonly used, machine-readable format.

 

  1. Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of these rights, please contact us. We will respond to your request within the time frames required by applicable data protection laws.

No fee required:

You have the right to access your personal data and exercise your other data protection rights without incurring a fee. However, if your requests are deemed to be unfounded, repetitive, or excessive, we may charge a reasonable fee. Additionally, in certain circumstances, we reserve the right to refuse your request. If any fees apply, we will inform you of the reasons for the charge before proceeding with your request.

What we may need from you:

To protect your personal data and ensure that only individuals with the right to access it do so, we may need to request specific information from you to confirm your identity when you exercise your data protection rights. This is a security measure aimed at preventing unauthorized disclosure of personal data. If necessary, we may reach out to you for additional information to expedite our response to your request.

Time limit to respond:

We aim to respond to all legitimate requests within one month. However, if your request is complex or if you’ve made multiple requests, it might take us longer to provide a response. In such cases, we will notify you and keep you updated on the progress of your request.

 

  1. GLOSSARY

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our operations to provide you with the best service, product, and secure experience. Before processing your personal data for our legitimate interests, we carefully consider and balance any potential impact on you, taking into account both positive and negative aspects, as well as your rights. We refrain from using 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 by law. For more details on how we assess our legitimate interests in specific activities and their potential impact on you, you can contact us.

Performance of Contract involves processing your data when 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.

Comply with a Legal or Regulatory Obligation refers to processing your personal data when it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

Third Parties

External Third Parties

We may disclose your personal data to various parties, acting as processors or joint controllers, to fulfill the purposes outlined in this privacy notice. This includes service providers offering IT and system administration services, professional advisers such as lawyers and auditors providing consultancy services, and authorities like HM Revenue & Customs and regulators based in the United Kingdom. We ensure that these third parties adhere to data protection laws, respect the security of your personal data, and process it only for specified purposes in line with our instructions.

 

Your Legal Rights

You have the right to:

As an individual, you hold specific rights regarding your personal data, governed by data protection laws. These rights empower you to request access to a comprehensive copy of your personal data, ensuring transparency and legality in its processing. Furthermore, you can seek correction of any incomplete or inaccurate information we may have. The right to request erasure allows you to ask for the removal of your personal data under certain circumstances. In instances where we rely on legitimate interests for processing, or if your data is used for direct marketing, you have the right to object. Additionally, you can request a restriction on the processing of your personal data in specific situations. A unique right involves requesting the transfer of your personal data to yourself or a designated third party in a machine-readable format. Should our processing rely on your consent, you reserve the right to withdraw it at any time; however, be aware that this might affect our ability to provide certain products or services. To exercise any of these rights, please reach out to us, and we will ensure a prompt and comprehensive response.