Privacy Policy

Last updated: February 08, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to ELM Compliance, Epcot Villa, Rue de la Ronde, Cheminee, Castel, Guernsey GY5 7GE.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Channel Islands and the United Kingdom
• Device means any device that can access the Service such as a computer, a mobile device or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to ELM Compliance, accessible from httpss://www.elmcompliance.com/
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
• • Type: Session Cookies
  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Data Protection (Bailiwick of Guernsey) Law, 2017

ELM Compliance Consultants Limited (“ELM”,“we”, “us”, “our”), are a Guernsey based Compliance Consultancy Business.  This Privacy Notice sets out how we obtain and use personal data about you before and after your relationship with us, in accordance with the Data Protection (Bailiwick of Guernsey) Law, 2017 (“the Guernsey DP Law”) and in accordance with the European Union General Data Protection Regulation (2016/679) (“GDPR”).

ELM is a “data controller”. This means that we are responsible for deciding how we hold and use your personal data. We are required under the data protection legislation detailed above to notify you of the information contained in this privacy notice.

This Privacy Policy relates to all clients, whether potential, ongoing or former clients (including their clients, employees and all key principals), service providers, intermediaries and all other such contacts of ELM (whether existing, future, declined, or past) and users of our website. We may update this Notice at any time.

Should you require further information in relation to this Privacy Notice, or wish to make a complaint in relation in respect of personal data please contact emma@elmcompliance.com in the first instance.

Data that we may collect

We only process personal data that is adequate, relevant and necessary for the purpose. The type of personal data we store varies based on the services offered.

The following categories of personal information may be gathered from You by us in order to carry out our business operations, including service provision:

• Name
• Contact details
• Business information required to meet legal and regulatory requirements
• Communication data such as emails, telephone calls and any documentation shared during the provision of our services
• Financial information, such as information related to payment
• Any other information you may provide to us on a voluntary basis

How We Use Your Personal Data
(Legal Basis for Processing)

The purposes and reasons for processing your personal data are detailed below: –

• In order to comply with obligations provided by laws, current regulations and legislation
• Where it is required in order for us to provide our services to you and fulfil our contractual obligations
• Where it is necessary for our legitimate business interests in conducting and managing our business
• To communicate with you within the parameters of our regular business relationship, via phone, email, or postal mail services, to respond to your inquiries, and manage client relationships.

Your Rights

You have the right to access any personal information that ELM processes about you and to request information about: –

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws.

Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.  It should be noted that ELM does not, at this time, utilise any automated decision making.

To exercise these rights or for any questions, please contact emma@elmcompliance.com (we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure)

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.

We may be required to share your personal data with:

• Third-party service providers assisting us in delivering our services
• Legal authorities when required by law or to protect our rights.

However, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

Transfers Outside the EU

Our website domain, email and office network are all within the European Economic Area (EEA). Should the exceptional occasion require your data to be transferred to and stored in countries outside the EEA, we take appropriate measures to ensure your data is protected when transferred.

Data Storage

ELM only ever retains personal information for as long as is necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable laws and regulations.
We have strict review and retention policies in place to meet these obligations and any documentation provided to us during the course of the provision of our services will be returned (if in hard copy) or destroyed in line with our data retention policy.

Data security

ELM takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction. This includes utilising popular, well known business IT platforms and software solutions.

Lodging A Complaint

ELM only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection law. If, however, you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with Emma.  If your complaint is not handled to your satisfaction, or you simply wish to go straight to the supervisory authority, you have the right to lodge a complaint with the Office of the Data Protection Commissioner in Guernsey.

Changes to this Privacy Policy

From time to time ELM will review this Privacy Policy and we reserve the right to make changes, additions or removals from this Privacy Policy at our discretion.  ELM would encourage all clients and interest parties to review this Privacy Policy at appropriate intervals.

Consent

You are not obligated to provide your personal information to ELM and you are freely able to withdraw your consent, however, as this information is required for us to provide you with our services and to comply with our legal obligations, we may not be able to offer any of our services to you without it.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: emma@elmcompliance.com