Name, contact details and other Personal Data
In various sections of the Website – e.g. if you decide to request a quote on the Website, or to subscribe to the Website’s Blog – you will be asked to submit information such as your name, phone / mobile numbers and email address, as well as information related to the company you currently work for and your position in that company. In addition, whenever you participate in surveys and other promotions, which may be available on the Website, as well as whenever you communicate with Elysium Concierge through the contact details provided in the Website, Elysium Concierge may collect additional information which you choose to provide. This is also the case regarding any information you choose to disclose in certain sections of the Website, which allow you to participate in a public forum or to contact Elysium Concierge directly.
Special categories of Personal Data
Certain areas of the Website include free text fields where you can write messages to Elysium Concierge (e.g., the Live Chat), or otherwise allow you to post various types of content on the Website, which may contain Personal Data. Where these fields are completely free, you may use them to disclose, or may post content which discloses (inadvertently or not) more sensitive categories of Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. The content you upload in these fields may also (inadvertently or not) include other types of sensitive information relating to you, such as your genetic data, biometric data or data concerning your health, sex life or sexual orientation. Elysium Concierge asks that you do not disclose any sensitive Personal Data on the Website, unless you consider this to be strictly necessary. If you do, this Personal Data may be processed by the Company based on your explicit consent.
Other persons’ Personal Data
Purposes of processing
Elysium Concierge intends to use your Personal Data, collected through the Website, for the following purposes: To verify your identity and assist you, in case you lose or forget your login / password details for any of Elysium Concierge's registration services, to allow you to access different restricted areas and sections of the Website (such as the Customer Portals), to request quotes, to send messages to Elysium Concierge, and to provide any other Services which you may request (“Service Provision”); For future marketing, promotional and publicity purposes, including carrying out direct marketing, market research and surveys, via e-mail and/or SMS (“Marketing”); To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services which Elysium Concierge believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested; to ensure the processing’s fairness and control for bias (“Profiling”); For compliance with laws, which impose upon Elysium Concierge the collection and/or further processing of certain kinds of Personal Data (“Compliance”); For development and administration of the Website, in particular by use of data analytics regarding how you and other users use the Website, as well as the information and feedback you provide, to improve our offerings (“Analytics”); To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).
Purposes of processing
Elysium Concierge's legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows: Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Elysium Concierge your Personal Data for these purposes; however, if you do not, Elysium Concierge will not be able to provide any Services to you. Marketing: processing for these purposes is based on Elysium Concierge's legitimate interest in promoting its goods and services to its existing and potential customer base. Though Elysium Concierge's customers are exclusively legal persons (as Elysium Concierge does not supply goods or services to individuals), this implies the use of personal data on contact persons within those legal persons, such as names and contact details. Given the fact that these direct marketing communications are directed at legal persons, that they are collected in the context of a request for a quote or an actual sale of Elysium Concierge's goods and services, and that individuals which receive these communications are entitled to opt-out at any time (including when their data is collected and within each communication sent), Elysium Concierge believes that its legitimate interest is not overridden by individuals’ rights, freedoms and interests. It is not mandatory for you to allow Elysium Concierge to use your Personal Data for these purposes, and you will suffer no consequence if you choose not to (aside from not being able to receive further marketing communications from Elysium Concierge). Profiling: processing for this purpose is based on your consent, given by accepting the use of profiling cookies. It is not mandatory for you to give consent to Elysium Concierge for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalization of your user experience regarding the Website). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information). Compliance: processing for this purpose is necessary for Elysium Concierge to comply with its legal obligations. When you provide any Personal Data to Elysium Concierge, Elysium Concierge must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations. Analytics: Information collected for this purpose is used to allow Elysium Concierge to understand how users interact with the Website and to improve the Website accordingly, with the aim of providing a better user experience. Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).
Recipients of Personal Data
Your Personal Data may be shared with the following list of persons / entities (“Recipients”): Persons, companies or professional firms providing Elysium Concierge with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; Entities engaged in order to provide the Services (e.g., hosting providers or email platform providers); Persons authorised by Elysium Concierge to perform technical maintenance (including maintenance of network equipment and electronic communications networks); Persons authorised by Elysium Concierge to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g. Employees of Elysium Concierge); Other companies within the Elysium Concierge Group; and Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities;
Transfer of Personal Data
Considering Elysium Concierge's worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. Elysium Concierge implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand.
Transfer of Personal Data
Personal Data processed for Service Provision will be kept by Elysium Concierge for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Elysium Concierge may continue to store this Personal Data for a longer period, as may be necessary to protect Elysium Concierge's interests related to potential liability related to the processing. Personal Data processed for Profiling will be kept by Elysium Concierge from the moment you give consent until the moment you withdraw the consent given. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Elysium Concierge, in particular as may be necessary to protect Elysium Concierge's interests related to potential liability related to this processing. Personal Data processed for Compliance will be kept by Elysium Concierge for the period required by the specific legal obligation or by the applicable law. Personal Data processed for Analytics and Misuse/Fraud will be kept by Elysium Concierge for as long as deemed strictly necessary to fulfil the purposes for which it was collected, unless you validly object to the processing of your Personal Data for these purposes (please see Section 8 for further information).
Data subjects’ rights
As a data subject, are entitled to exercise the following rights before Elysium Concierge, at any time: Access your Personal Data being processed by Elysium Concierge (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data; Correct or update your Personal Data processed by Elysium Concierge, where it may be inaccurate or incomplete; Request erasure of your Personal Data being processed by Elysium Concierge, where you feel that the processing is unnecessary or otherwise unlawful; Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing; Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Elysium Concierge, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller; Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Elysium Concierge from processing your Personal Data; or Withdraw your consent to processing (for Profiling). Please note that most of the personal information you provide to Elysium Concierge can be changed at any time, including your email preferences, by accessing the user profile you can create on the Website. You can object to the processing of your Personal Data for Marketing also by selecting the appropriate link included at the bottom of every marketing e-mail message received. Aside from the above means, you can also exercise your rights described above by sending a written request to Elysium Concierge at the following address: firstname.lastname@example.org In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through the Website is unlawful. email@example.com