Privacy Policy

Who we are:

For the purpose of this Privacy Policy, “you” or “your” means any end user accessing or receiving our services or using our Website (www.elite-dynamics.com), and “we” or “us”, “our” or “Elite Dynamics” means (as relevant):

• Elite Dynamics UK Limited, company number 09698342 with our registered office address at 8-10 Hill Street, London, England, W1J 5NG.
• Elite Dynamics Canada Ltd with head office at 79 Wellington ST West, Suite 30th Fl., Toronto, Ontario, M5K1N2, CA.
• Elite Dynamics USA Ltd with head office at 251 Little Falls Drive, Wilmington, County of New Castle, 19808 DE.

How we process personal data:

At Elite Dynamics we take your privacy seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, how you can instruct us if you prefer to limit the use of that personal data and the procedures that we have in place to safeguard your privacy. Our privacy practices may vary among the countries in which we operate, which include the UK, US and Canada, to reflect local practices and legal requirements.  For the purpose of the retained English-law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), we are regarded as “independent controller” of your personal data when we collect it (equivalent to “business” under US data protection law and “organization” under Canadian data protection law).

By using or accessing our Website, communicating with us or using our services, you understand and agree that we will collect and process your personal data in accordance with this privacy policy. If you do not agree with this privacy policy, you must not use our services, access our Website or submit information to us through or in connection with our services, the Website or otherwise.

The person responsible for how we handle personal data is Jamaine Campbell and you can contact him by email at: jcampbell@elitedynamics.co.uk

Types of personal data we collect and use

Personal data provided by you

Personal data (equivalent to “personal information” in the US and Canada) means any information about an individual from which that person can be identified. In the course of operating our computer software business, we collect personal data when you provide it to us, such as:

• Identity Data: your name, date of birth, national insurance number.
• Contact Data: postal address, email address and phone numbers.
• Financial and Transaction Data: financial and payment details, insurance details.
• Education and Employment Data: information regarding your education, employment history, qualifications and skills when you apply for a job with us, job title and CV.
• Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this Website.
• Usage Data: information about how you interact with and use our website, products and services.
• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyze general trends in how users are interacting with our website to help improve the website and our service offering.

Personal data provided by third parties

Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us provide services to you and to improve and personalize our service to you. If you apply for a job with us, we may receive information from the people who provide references.

Personal data about other individuals

If you give us information on behalf of someone else as an alternate contact, referee or next of kin, you confirm that the other person has agreed that you can:

• give consent on his/her behalf to the processing of his/her personal data;
• receive on his/her behalf any data protection notices; and
• if relevant, give consent to the transfer of his/her personal data abroad.

Special category data

We will not usually ask you to provide special category data. We will only ask you to provide such information if we need it for a specific reason. If we request such information, we will explain why we are requesting it and how we intend to use it.

Special category data (equivalent of “sensitive personal information” and “sensitive data” under Us and Canadian data protection laws) includes information relating to your ethnic origin, political opinions, religious beliefs, whether you belong to a trade union, your physical or mental health or condition, sexual life, and whether you have committed a criminal offence. We will only collect such information with your explicit consent.

Children

We do not knowingly collect personal data relating to children. If you are a parent or guardian of a child under the age of 18 and think that we may have information relating to that child, please contact us. We will ask you to prove your relationship to the child but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.

How and when do we collect information from you?

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

• Your interactions with us. You may directly give us your personal data through our Website, by corresponding with us by phone email or otherwise. This includes personal data you provide when you:
  • visit our Website and submit a form;
  • call us to make an enquiry;
  • use our Website to sign up to, participate in or receive a service from us, such as requesting a quote online or entering a live chat.
• Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties (such as credit reference agencies).

We may monitor and record communications with you (such as telephone conversations and emails).

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device such as a mobile telephone or tablet) when you use our Website. We use cookies and other similar tracking technologies such as pixels on our Website. We do this to find out things such as the number of visitors to the various parts of the Website. This information is only processed in a way which does not identify you individually. We use analysis software to look at IP addresses and cookies to improve your experience as a user of our website. We do not use this information to develop a personal profile of you. If we do collect personally identifiable information, we will be up front about this. We will make it clear when we collect personal data and will explain what we intend to do with it.

You can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on our use of cookies, please see our Website cookie policy.

For further information on cookies generally, visit www.aboutcookies.org or www.allaboutcookies.org.

Reasons we can collect and use your personal data

Depending on the location from which you access the Website or are otherwise based when sharing your personal data with us, the law may require us to have a legal basis for collecting and using your personal data. We rely on a different lawful basis for collecting and using personal data in different situations, including:

• Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.

 

• Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).

 

• Legal obligation: we may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

 

• Consent: we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Purpose	Type of data	Legal basis
To register you as a new customer	(a)   Identity Data (b)   Contact Data	(a)   Performance of a contract with you.
To prepare our professional service agreement with you and arrange insurance coverage if required	(a)   Identity Data (b)   Contact Data	(a)   Performance of a contract with you.
To process and deliver our products/services, including: (a)   dealing with payment for our products/services; and (b)   collecting payments owed to us.	(a)   Identity Data (b)   Contact Data (c)    Financial and Transaction Data	(a)   Performance of a contract with you; and/or (b)   Necessary for our legitimate interests to recover payments owed to us.
To manage our relationship with you, including: (a)   responding to your enquiries; (b)   managing any accounts you hold with us; (c)    contacting you for reasons related to the service you have signed up for or to provide information you have requested; (d)   notifying you of any changes to our Website or to our services that may affect you; and (e)   resolving disputes; (f)    undertaking a credit check; and (g)   notifying you about changes to our terms or privacy notice.	(a)   Identity Data (b)   Contact Data (c)    Profile Data (d)   Marketing and Communications Data	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; and/or (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you.
To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, detect and prevent fraud and prevent offensive, inappropriate or objectionable content being sent to or posted on our Website).	(a)   Identity Data (b)   Contact Data (c)    Technical Data	(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 reorganization or group restructuring exercise); and/or (b) Necessary to comply with a legal obligation.
To use data analytics to improve our Website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.	(a)   Technical Data (b)   Usage Data	(a) 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 send you relevant marketing communications and make personalized suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data.	(a)   Identity Data (b)   Contact Data (c)    Technical Data (d)   Usage Data (e)   Profile Data (f)    Marketing and Communications Data	(a) Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business).

 

In certain jurisdictions the legal bases may also include consent, where appropriate for compliance with local data protection laws, and we will obtain your consent in those jurisdictions where relevant.

If you apply for a job with us, we will collect and use personal data to process your application and check references. If you accept a job with us, we will collect and use your personal data to enter into an employment contract with you and to administer the employment relationship, including making payments to you, accounting for tax, ensuring safe working practices, monitoring and managing staff access to systems and facilities, monitoring absences and performance and conducting assessments. Our use of your personal data in such ways is covered by internal privacy notices that we will make available to you at the time.

If we propose to use your personal data for any other purpose, we will ensure that we notify you first. If we need your consent to use your personal data for other purposes, we will give you the opportunity to opt in or to refuse. If you opt in, you will be able to opt out at any time.

Opting out of marketing

If you would like to stop receiving email newsletters, you can also click on the “unsubscribe” button at the bottom of the email newsletter. It may take a few days for this to take place or if you do not wish to continue receiving these communications, you can opt out at any time. See ‘What rights do you have?’ below for further information. You can ask us to stop contacting you in this way, you can also ask us to start again at any time

When will we contact any other person about you?

If you provide us with details of any other person we can contact to discuss your account, we may contact that person and discuss and share the details of your account with that person and deal with that person in relation to your account as if that person was you. We may particularly want to do this if we are unable to get in touch with you for any reason. If you change your mind, you can email or write to us and have this person taken off your account as an alternate contact person (see ‘How can you contact us?’ below).

If you provide us the details of a person who we can contact for a job reference, we may contact that person in connection with your job application.

Who your information might be shared with

We may disclose your personal data where necessary with the parties set out below for the abovementioned purposes.

• service providers under contract with us to support our business operations, such as fraud prevention, debt collection, payroll, technology services;
• our professional advisors
• trade associations of which we are a member;
• law enforcement or government agencies in connection with any investigation to help prevent or detect unlawful activity;
• any person or agency if we need to share that information to comply with the law or to enforce any agreement we may have with you or to protect the health and safety of any person;
• any person who you have named as a person we can contact to discuss your account;
• any person who is your agent or representative, such as the holder of a power of attorney, a legal guardian or person administering a will;
• any person who we are negotiating with as a potential buyer of our business or property or if we are proposing to merge our business with another business;
• credit card associations if specifically required.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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 our instructions.

Keeping your personal data secure

We have appropriate security measure in place to prevent personal data from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal data to those who have a genuine business need to know it. Those people processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality.

We will use technical measures to safeguard your personal data, for example:

• Access to your customer account is controlled by a password and user name that are unique to you;
• we store your personal data on secure servers within the Microsoft Azure environment; and
• payment details are encrypted on a secure server.

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

While we will use all reasonable efforts to keep your personal data safe, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).

Our Website contains links to websites and applications owned and operated by other people and businesses. These third-party sites have their own privacy policies and use their own cookies and we recommend that you review them before you provide them with personal data. They will tell you how your personal data is collected and used whilst you are visiting these other websites. We do not accept any responsibility or liability for the content of these sites, or the use of your information collected by any of these other sites and you use these other sites at your own risk.

If you want detailed information from ‘Get Safe Online’ on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

International Transfers

Elite Dynamics is an international business. The personal data that we collect may be stored and processed in the country where it was collected, in the countries where we operate or in other locations, including third party data centers. We take all reasonable steps to protect personal data, regardless of the country in which it is held.

This means that your information may be stored, processed, accessed, or used in countries whose privacy laws differ from and may offer less protection than those applicable in the jurisdiction where the personal data was collected. Whenever we transfer your personal data internationally to countries whose privacy laws do not offer an adequate, substantially similar or otherwise sufficient level of protection required under the applicable laws of the jurisdiction in which the personal data was originally collected, we will implement appropriate measures to meet the requirements of the relevant data protection frameworks. These safeguards may include:

• entering into contractual agreements that impose strict data privacy and security obligations (e.g. the European Commission’s Standard Contractual Clauses or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses). You may request a copy of these safeguards by contacting us at jcampbell@elitedynamics.co.uk;
• applying technical and organizational security measures (such as encryption, access controls, and data minimization protocols);
• conducting data transfer risk assessments or legal evaluations, where required under applicable laws;
• ensuring compliance with US transfer regulations; or
• relying on the explicit consent of the individual, where permitted or required under relevant law.

How long do we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal 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 unauthorized 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.

What rights do you have?

Depending on your country, you may have the following rights:

• Request a copy of your information which we hold (subject access request);
• Request correction of any mistakes in your information which we hold. 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 the erasure of personal data concerning you in certain situations. 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;
• Request to restrict our processing of your personal data in certain circumstances;
• Object in certain other situations to our continued processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object;
• Object (marketing). Require us to stop contacting you for direct marketing purposes;
• Object (automated decisions). Object to decisions being taken by automated means which produce legal effects concerning you or which affect you significantly; and
• Request the transfer of your personal data which you have provided to us to you or a third party, in a structured, commonly used and machine-readable format. 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.

Further information on the applicable rights is available from:

• UK: Information Commissioner’s Office
• US: FTC (or applicable state attorneys)
• Canada: Office of the Privacy Commissioner of Canada

If you would like to exercise any of these rights, please:

• Email, call or write to us (see ‘How to contact us’ below), and
• Let us know the information to which your request relates, including any account or reference numbers, if you have them

We will not charge any fee for any of these services in most cases.

How to contact us

We hope that we can resolve any query or concern you raise about the way we use your personal data. Please contact us if you have any questions about this privacy policy or the information, we hold about you.

If you wish to contact us, please send an email to our Data Protection Officer:

Jamaine Campbell
E. jcampbell@elitedynamics.co.uk

Or write to us at:

Elite Dynamics (UK) Limited
8-10 Hill Street
Mayfair
London
W1J 5NG

Or call us on +44 (0) 161 641 8926.

The UK GDPR also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/make-a-complaint/ or telephone 0303 123 1113.

Changes to the privacy policy

This Privacy Notice was published on 22/02/2020 and last updated on 21/10/2025. We may change this Privacy Notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.

Alternative formats?

If you would like this policy in another format (for example: audio, large print, braille) please contact us (see ‘How can you contact us?’ above).