Privacy Policy

Elifinty respects your privacy and is committed to protecting your personal data and the privacy and security of all personal information.

Purpose of this privacy policy

This privacy policy aims to give you information on how Elifinty collects and processes your personal data through your use of the Elifinty App and our Services (and all related web sites, applications and online services and tools where this policy is referenced, regardless of how you access or use them, including mobile devices) and when you register as a user and interact with us through our services. It also tells you what your privacy rights are and how the law protects you.

We will let you know if other Privacy Policies apply

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting, or processing, certain types of personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy. If you would like any additional information about our services or how the Elifinty App processes your personal data, please contact support@elifinty.com

End to End Encryption of your Personal Data

Unless you agree otherwise, all of your activity on the Elifinty App is encrypted via a secure and modern cypher suite, meaning data exchanged between you and the Elifinty App and anyone you chose to share your data with is safe from prying eyes.

1. Important Information and Who We Are

Whilst we are mainly a processor of your personal data in some circumstances, we are a data Controller

Elifinty is the controller in respect to certain uses of your personal data (collectively referred to as Elifinty, “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Full name of legal entity: Elifinty Ltd (no. 11345938), a company duly incorporated and existing under the laws of England & Wales, with its registered address at 124 City Road, London EC1V 2NX (hereinafter referred to as “Elifinty”)

Email address: privacy@elifinty.com

Making a Complaint

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

Changes to our privacy policy Your duty to inform us of changes to your personal data

We keep our privacy policy under regular review. From time to time, we may update this Privacy Policy and reserve the right to do so. Updates may be made to reflect changes in applicable privacy law or best practices.

We will place a notice online when we make changes to this Privacy Policy but will contact you when those changes are material in regards to the disclosure or use of your Personal Information. We will contact you by emailing you at the email associated with your account.

Your duty to inform us of changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your interaction with third parties

The Elifinty App allows you to interact with our partners and other third parties and to share your Personal Data with them. Please see section 5 below for more information.
Where you agree to allow any third parties to receive, collect or share data about you, we are not in control of those third-parties and are not responsible for their privacy statements or the way in which they collect or use your data.

You must ensure that you are comfortable with and request details of and read the privacy policy of any third party you share your Personal Data with.

While Elifinty has no visibility of your private information, we do examine trends and patterns to inform business decisions.

We may use the services of other businesses, for example, for data storage. Where we share any of your information with these third parties we will encrypt your data and it will be properly protected by the terms of our contract with these third parties.

Please Note: The Elifinty App and our Services are made available to you as a service to support your financial decisions and accounting, except to the extent detailed in the Elifinty Terms of Use we do not engage in any correspondence, or the relationship, between you as a user of the Elifinty App and any services you make use of, or which are made available to you through it. In particular, other than in the provision of the Elifinty App and our Services we do not participate in any part of any service or any contract for services which may be provided to you by any third party.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our App or our Services may become inaccessible or not function properly. Please see our Cookie Policy for more details.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We do not collect and hold your Personal Data other than for the purposes of supporting you in your use of our App. The collection, use, storage and transfer of your personal data is limited to:

Data processed by us as part of your use of the Elifinty App and Services

– Technical Data which includes your internet protocol (IP) address, your login data, browser type and version, hardware information, time zone setting, browser plug-in types and versions, operating system and website, and other technology on the devices you use to access the App.

– Usage Data which includes anonymised information about how you use our App, products and services. This will also include, for example, an anonymised record of any support request.

– Marketing and Communications Data which includes your preferences in receiving marketing from us and our third party partners and your communication preferences. This includes statistical data we collect on usage and where you provide us with your e-mail address.

We also collect, use and share other Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

If you fail to provide personal data

If you fail to provide personal data
Where we need to collect or process your personal data in order to provide a service and you do not provide that data, you may not be able to access to a service which you have requested, but we will notify you if this is the case at the time.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions. This includes personal data you provide when you: (a) create a Elifinty account; (b) subscribe (or are subscribed) to a Elifinty service; (c) request marketing to be sent to you; (d) enter a promotion or survey; or (e) give us feedback or contact us.

Automated technologies or interactions. As you interact with the Elifinty App, we will automatically collect Technical Data about your equipment, usage and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

– To provide you with services in relation to the Elifinty App (Performance of a contract)
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
– Where we need to comply with a legal obligation.
– Where we rely on your consent such as when you download the Elifinty App.

For further information please see 10. Glossary.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Recommendations from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of your use of the Platform or any associated services.

5. Sharing Your Personal Data

We may have to share your personal data in the following context.

• Where you have stored information in the App or our Services, we may share it or request to share it in specific circumstances, such as valid requests for information from third parties. We may also request information to validate certain authentication requirements.
• Service providers acting as processors who provide our IT and system administration services.
• Providers of our cloud services such as AWS, Azure and Google.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Sale of our business. If Elifinty sells its assets the principles of this privacy policy will still apply. We have no access to your encrypted personal information so neither will any other organisation, but Elifinty may provide anonymised statistical information to third parties.
• Google Analytics information:
  We use Google Analytics for some products or websites. The information that we collect through Google Analytics is not linked to you as a person and your identity cannot be derived. We cannot provide you with this information as it is not linked to any of your identifying details.
  You can make an access request to Google here: https://support.google.com/policies/contact/sar

You should carefully read the privacy policies of any organisation you share your information with to understand how they will use your personal information before you share any information with them.

Where you agree to share your Personal Data

You will be informed of any transfer of your personal data prior to it taking place and the extent of the data being shared.

In these cases, during the transfer, we will, at all times, control and be responsible for the use of your personal data.

Where we engage with third parties as part of our services to you we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We contractually oblige our third-party partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with your instructions.

To help constantly improve and tailor the service we provide to you through our App or Services, we may use aggregated information so that we can administer and improve our services, analyse trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymised format.

6. International Transfers

Where we use other organisations to support your use of our services, we may transfer your personal data outside the United Kingdom (UK) or European Economic Area (EEA). We have contract terms in place that contain obligations on any third party to safeguard your information.
In some countries, for legal or practical reasons, Elifinty may have to store personal information in that country.

Whenever we transfer your personal data out of the UK or EEA, we ensure an appropriate 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 UK government or European Commission.
• We may use specific contracts approved by the UK government European Commission which give personal data the same protection it has in Europe.

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

If we decide or are obliged to send or store your personal information in a particular country, we will update you and describe the protections we have put in place.

7. Data Security and Location

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We always keep personal information in secure locations within the UK/EU with strict access controls.

In addition, we limit access to your personal data to those employees and other third parties who strictly need to know. They will only process your personal data on your instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as you have an account with us. The information you add to your account or provide as part of using a product or service remains until you delete the account.

We may retain certain of your personal contact data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please e-mail privacy@elifinty.com

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You can delete your account or certain information from within our App / Services.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data “Data Portability” to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where 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. In respect to Elifinty, that is the performance of our agreement with you to make the App and its services available.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.