ELM (Legal Services) Ltd (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.elm-online.co.uk you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 (‘the Act’) and GDPR, the data controller is ELM (Legal Services) Ltd, of Kingsland House, Gas Lane, Bristol BS2 0QL.
DATA WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site www.elm-online.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
- Information purchased from third-party data companies.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
THE LAWFUL BASIS FOR PROCESSING YOUR DATA
We collect Customer Personal Data in order for our Consultants to make contact with the Data Subject to discuss our services. Should the data subject purchase a service from ELM (Legal Services) Ltd we collect further personal data in order to produce an accurate and legally binding Will. Should the data subject wish to purchase further services including, but not limited to Life-Time Trusts or Lasting Powers of Attorney ELM (Legal Services) Ltd may be required to collect further data. ELM (Legal Services) Ltd will only collect what is strictly necessary to carry out the required processing.
The data that we collect from the forms on this website or through inbound telephone or email enquiries is processed under consent. The Data Subject can remove their consent at any time by emailing firstname.lastname@example.org.
The data that we purchase from third-party data companies and data brokers is processed under legitimate interest. This data would have been collected under the basis of legitimate interest for legal service marketing. This data may only be only contacted once within 30 days of purchase unless otherwise authorised by the data subject.
We collect the Data Subjects personal details on our paper instruction forms and electronic instruction forms in order to fulfil our contractual obligations to our customers and produce any of the legally binding products that we provide to our clients. Transactional data also falls under the Contractual heading – that is data that we collect in order to process payments.
Your Personal Data shall not be kept for longer than is necessary, and retention shall be in accordance with the following rules:
- The retention period during which your Personal Data are kept shall be reviewed periodically;
- This retention period shall be adequate for the purpose/s of the Processing, your Personal Data shall not be kept once the purpose/s has/have been accomplished;
- Once they are no longer required, your Personal Data shall be deleted or anonymized in a secure manner ensuring protection from unlawful or wrongful access.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form);
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If ELM (Legal Services) Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
At any point whilst ELM (Legal Services) Ltd is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access– you have the right to request a copy of the information that we hold about you. Please be aware that we may require a sufficient form of identification before information on your personal data is can be released.
- Right of rectification– you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten– in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to the restriction of processing– where certain conditions apply you have a right to restrict the processing.
- Right of portability– you have the right to have the data we hold about you transferred to another organisation.
- Right to object– you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling– you also have the right not to be subject to the legal effects of automated processing or profiling.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In the event that you wish to make a complaint about how your personal data is being processed ELM (Legal Services) Ltd or its partners and/or Consultants, you have the right to complain to ELM (Legal Services) Ltd. The details for this contact is as follows:
James D Emsley
ELM (Legal Services) Ltd
If you do not get a response within 30 days you may complain to the Information Commissioners Office at https://www.ico.org.uk/make-a-complaint/
ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.