Privacy Policy

Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

 

What personal information do we collect from the people that visit our blog, website or app?

 

When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, credit card information or other details to help you with your experience.

 

When do we collect information?

 

We collect information from you when you register on our site, place an order, Open a Support Ticket or enter information on our site.


 

How do we use your information?

 

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

       To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.

       To allow us to better service you in responding to your customer service requests.

       To administer a contest, promotion, survey or other site feature.

       To quickly process your transactions.

 

How do we protect your information?

 

We do not use vulnerability scanning and/or scanning to PCI standards.

An external PCI compliant payment gateway handles all CC transactions.

We do not use Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

 

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

 

All transactions are processed through a gateway provider and are not stored or processed on our servers.

 

Do we use 'cookies'?

 

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.


We use cookies to:

       Help remember and process the items in the shopping cart.

       Understand and save user's preferences for future visits.


You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.


If users disable cookies in their browser:

 

If you turn cookies off, Some of the features that make your site experience more efficient may not function properly.Some of the features that make your site experience more efficient and may not function properly.


 

Third-party disclosure

 

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety. 

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

 

Third-party links

 

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

 

Google

 

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We have not enabled Google AdSense on our site but we may do so in the future.

 

COPPA (Children Online Privacy Protection Act)

 

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not knowingly collect information from children under 13

We do not let third-parties, including ad networks or plug-ins collect PII from children under 13.


In order to remove your child's information please contact the following personnel:

emttim


We adhere to the following COPPA tenants:

       Parents can review, delete, manage or refuse with whom their child's information is shared through contacting us directly.

or contacting us directly.

 

For our friends in the EU. Below is in compliance with the GDPR the EU put out. Any of the above that does not comply with the EU GDPR is amended with the blow policy. This is only for those living in the EU and does not pertain to any other persons. 

 

Data protection policy

Context and overview                                                                                           Key details

·         Policy prepared by:                                         emttim

·         Approved by board / management on:          17/05/2018

·         Policy became operational on:                       17/05/2018

·        Next review date:                                            17/05/2023

Introduction

Elementum Gaming needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Elementum Gaming:

·        Complies with data protection law and follow good practice

·        Protects the rights of staff, customers and partners

·        Is open about how it stores and processes individuals’ data

·         Protects itself from the risks of a data breach

Data protection law

The Data Protection Act 1998 describes how organisations — including Elementum Gaming— must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1.      Be processed fairly and lawfully

2.      Be obtained only for specific, lawful purposes

3.      Be adequate, relevant and not excessive

4.      Be accurate and kept up to date

 

5.      Not be held for any longer than necessary

6.      Processed in accordance with the rights of data subjects

7.      Be protected in appropriate ways

8.      Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

 

 

People, risks and responsibilities                                                                     Policy scope

This policy applies to:

·        The head office of [company name]

·        All branches of [company name]

·        All staff and volunteers of [company name]

·         All contractors, suppliers and other people working on behalf of [company name]

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

·        Names of individuals

·        Postal addresses

·        Email addresses

·        Telephone numbers

·         …plus any other information relating to individuals

Data protection risks

This policy helps to protect [company name] from some very real data security risks, including:

·        Breaches of confidentiality. For instance, information being given out inappropriately.

·        Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

·         Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with [company name] has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

 

However, these people have key areas of responsibility:

·         The board of directors is ultimately responsible for ensuring that Elementum Gaming meets its legal obligations.

·         The Data Protection Officer, Paronity, is responsible for:

o    Keeping the board updated about data protection responsibilities, risks and issues.

o    Reviewing all data protection procedures and related policies, in line with an agreed schedule.

o    Arranging data protection training and advice for the people covered by this policy.

o    Handling data protection questions from staff and anyone else covered by this policy.

o    Dealing with requests from individuals to see the data Elementum Gaming holds about them (also called ‘subject access requests’).

o    Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

·         The IT Manager, Paronity, is responsible for:

o    Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

o    Performing regular checks and scans to ensure security hardware and software is functioning properly.

o    Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

·         The marketing manager, emttim, is responsible for:

o    Approving any data protection statements attached to communications such as emails and letters.

o    Addressing any data protection queries from journalists or media outlets like newspapers.

o    Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

 

General staff guidelines                                                                                      

·         The only people able to access data covered by this policy should be those who need it for their work.

·         Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

·         Elementum Gaming will provide training to all employees to help them understand their responsibilities when handling data.

·         Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

·         In particular, strong passwords must be used and they should never be shared.

·         Personal data should not be disclosed to unauthorised people, either within the company or externally.

·         Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

·         Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

 

 

Data storage                                                                                                            

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

·         When not required, the paper or files should be kept in a locked drawer or filing cabinet.

·         Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.

·         Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

 

·         Data should be protected by strong passwords that are changed regularly and never shared between employees.

·         If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.

·         Data should only be stored on designated drives and servers, and should only be uploaded to an

approved cloud computing services.

·         Servers containing personal data should be sited in a secure location, away from general office space.

·         Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.

·         Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

·         All servers and computers containing data should be protected by approved security software and a firewall.

 

 

Data use                                                                                                                    

Personal data is of no value to Elementum Gaming unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

·         When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

·         Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

·         Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.

·         Personal data should never be transferred outside of the European Economic Area.

·         Employees should not save copies of personal data to their own computers.

Always access and update the central copy of any data.

 

 

Data accuracy                                                                                                          

The law requires Elementum Gaming to take reasonable steps to ensure data is kept accurate and up to date.

 

The more important it is that the personal data is accurate, the greater the effort Elementum Gaming should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

·         Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

·         Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

·         Elementum Gaming will make it easy for data subjects to update the information Elementum Gaming holds about them. For instance, via the company website.

·         Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

·         It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

 

 

Subject access requests                                                                                       

All individuals who are the subject of personal data held by Elementum Gaming are entitled to:

·         Ask what information the company holds about them and why.

·         Ask how to gain access to it.

·         Be informed how to keep it up to date.

·         Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at . The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

 

Disclosing data for other reasons                                                                    

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Elementum Gaming will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

 

Providing information                                                                                          

Elementum Gaming aims to ensure that individuals are aware that their data is being processed, and that they understand:

·         How the data is being used

·         How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

[This is available on request. A version of this statement is also available on the company’s website.]

Third Parties

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