Privacy & Cookies

PRIVACY STATEMENT AND USE OF COOKIES

Version: 22/05/2018

Who are we?

At Elton, we strive to protect and respect your data in accordance with the EU General Data Protection Regulation (GDPR) 2016/679 of 27 April 2016. This privacy statement explains when and why we collect personal information, how we use that information, the conditions that apply to sharing that information with others and how we protect and secure that information. 

This privacy statement applies to the use of our products and our activities in relation to sales, marketing and fulfilling contracts with customers. The privacy statement also applies to people who apply for a position at Elton, for people who register for the newsletter, who complete a contact form on the website, or who post messages on our social media. 

When do we collect personal data?

• When you use our products.
• When you communicate with us personally in writing, by telephone, via social media or via our websites.
• When we collect personal information using other legitimate sources, such as external data collectors, partners, public sources or social networks. We only use this data if you have given these sources permission to share your personal data with others.
• The data is only used for a legitimate purpose and if that purpose is not overridden by your privacy considerations. Before collecting data, we perform an analysis to assess whether a mutual interest exists for you and Elton.

Why do we collect personal data?

We mainly collect and use personal data in order to perform direct selling, direct marketing and customer service activities. We also collect data about suppliers, partners, job applicants and the company´s employees.

We may use your information for the following purposes:

• To send you the requested marketing communication material. This may include information about our products and services, events, activities and product promotions and services offered by our partners.
• To send you information about the products and services that you purchase from us.
• For performing direct sales activities in cases where there is a clear legitimate and mutual interest.
• To reply to a contact form or other type of web form that you have completed on www.elton.nl and/or one of the subpages.
• To follow up on enquiries that we have received (customer support, emails or telephone calls).
• To grant access to Elton´s Ellen portal.
• To comply with contractual obligations, such as order confirmations, licence details, invoicing, reminders and suchlike. The contract can be concluded directly with Elton or with one of Elton´s customers.
• To inform you of a disruption in our service provision (system messages).
• To contact you in order to assess your views regarding our products and services.
• To process a job application.

Legal basis for collecting personal data

Collecting personal data based on contracts

We use personal information in order to comply with the obligations that ensue from our contracts and agreements with customers, partners and suppliers.

Legitimate interest

We may use personal data if doing so serves a legitimate interest and the privacy considerations of those involved do not override that interest. In most cases, we have performed an analysis that indicates the existence of a mutual interest for both Elton and the individual person concerned in order to determine whether there is a legal basis for data collection. This legal basis is primarily related to sales and marketing goals. We will always inform you of your privacy rights and state the purpose for which we collect personal data.

What personal data do we collect?

In addition to the name of your organisation and the associated contact information, we also record your name, telephone number, position and email address. We may also keep a record of feedback, comments and questions which we have received from you via service-related communication and activities such as meetings, telephone conversations, documents, chats and email messages. We may record IP addresses and activities on our websites via our applications and websites.

If, for example, you upload photos or videos to our social media or post messages or comments, this information can be read by everybody who accesses those social media facilities and used for purposes over which neither Elton nor you have any control. Therefore, Elton is not responsible for the information that you post on Elton's social media facilities. 

If you apply for a position at Elton, we keep a record of the information that you provide during the job application procedure.

How long do we store your personal data?

We store personal data for as long as required for the purpose for which the personal data was collected and in doing so also allow for the fact that we must be able to answer your questions or resolve possible problems, comply with the legal requirements of the applicable legislation, be able to handle legal claims/complaints and must be able to protect the data.

This means that we store your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will remove this data in a secure manner. We may process data for statistical analysis, however the data is anonymized beforehand.

Rights in respect of your personal data

You have the following rights in respect of your personal data:

• You are entitled to request a copy of your personal data held by Elton.
• You are entitled to correct your personal data if it is incorrect or out-of-date.
• If you are a partner and use the Ellen portal, you can ask us to edit your data.
• You are entitled to request removal of your personal data if Elton no longer needs to store this data.
• You are entitled to withdraw your consent regarding use of your personal data at any time. Please take into account that you may still receive system-related and administrative notifications from Elton, such as order confirmations, system messages and reports regarding activities within your account.
• You are entitled to ask Elton to issue your personal data and, if possible, send this information directly (in a transferable format) to another data controller if the processing involved is based on consent or a contractual obligation.
• You are entitled to request an embargo on further processing of your data in the event of a dispute regarding accuracy or the way in which your personal data is processed.
• You are entitled to object to processing of your personal data if the data processing is based on a legitimate interest and/or direct marketing.

You can send your questions about your privacy rights to privacy@elton.nl.

The use of cookies and beacons

We use cookies to collect information about how you navigate on Elton's websites. Information about website navigation includes standard web browser information such as the browser type and browser language, your IP address (Internet Protocol) and the actions performed on Elton’s websites such as pages that have been viewed and links that have been clicked.

This information is used to make websites operate more efficiently, to deliver business and marketing information to the owners of the site and to collect personal data such as the browser type and operating system, pages that have been viewed, the path followed through the site, etc. in order to gain a better understanding of how visitors use the website.

Cookies and similar technologies help us make the website more user-friendly and also allow us to detect security threats and misuse. If used independently, cookies and web beacons cannot identify you personally. 

You can set your browser to block the cookies referred to above. Go to Settings in your browser or the specific tab that your browser indicates for this.

With whom do we share your data?

We do not share, sell, lease or trade your information with/to any third parties without your permission, with the exception of external service providers working on our behalf. We may transfer your information to our distributors, agents, subcontractors and other related organisations so that they can offer you services on our behalf.

In the event of a statutory obligation:

We will release your personal information if this is a statutory obligation and if we, as a company, have reason to believe that releasing your information is required in order to protect the rights of our company and/or comply with a court procedure, court order or legal procedure. We will however do everything possible to ensure that your privacy rights remain protected.

Use of subcontractors (processors and sub processors)

We may use subcontractors in order to process your personal data on our behalf. We are responsible for ensuring that these subcontractors comply with this privacy statement and the applicable data protection legislation by having them sign a data processing agreement (DPA).

If a subcontractor processes personal data outside the EU/EEA, the associated processing must comply with the EU framework for privacy, the EU standard contractual causes relating to transfer of personal data to third countries, or a different, specifically identified legal basis for transferring personal data to a third country.

If a new subcontractor is added, or a change of subcontractor takes place that is related to our service provision, customers will be informed accordingly in compliance with our terms and conditions for processors. Our terms and conditions for processors include a list of approved subcontractors; this information is available on our website.

Alterations to this privacy statement

Elton reserves the right to alter this privacy statement at any time. The valid version is always available on our website. We request you to regularly read this privacy statement to ensure that you are in agreement with possible alterations.

If the alterations we make significantly change the nature of our privacy statement, we will inform you of this by email or via notifications in our applications.

Your right to submit a complaint to a supervisory authority

If you are dissatisfied about the way in which your personal data is processed, please contact us in the first instance via privacy@elton.nl. If you remain dissatisfied, you are entitled to contact the national supervisory authority directly and request a decision. In that case, you can contact the Netherlands Data Protection Supervisor (Autoriteit Persoonsgegevens) via www.autoriteitpersoonsgegevens.nl.