Last Updated On 11-Jun-2024
Effective Date 11-Jun-2024

This Privacy Policy describes the policies of Elements on the collection, use and disclosure of your information that we collect when you use our website ( ????.co.uk)(the “Service”). By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service.

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service. The revised Policy will be effective 180 days from when the revised Policy is posted in the Service and your continued access or use of the Service after such time will constitute your acceptance of the revised Privacy Policy. We therefore recommend that you periodically review this page.

Information We Collect:

We will collect and process the following personal information about you:

1. Name
2. Email
3. Phone

How We Use Your Information:

We will use the information that we collect about you for the following purposes:

1. Marketing/ Promotional
2. Creating user account
3. Testimonials
4. Customer feedback collection
5. Enforce T&C
6. Support
7. Administration info
8. Targeted advertising
9. Dispute resolution
10. Manage user account

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

How We Share Your Information:

We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below:

1. Ad service
2. Analytics

We require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.

1. We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights. If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.

Retention Of Your Information:

We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

Your Rights:

Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at ????@?????. We will respond to your request in accordance with applicable law.

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.

Cookies Etc.

Our website uses cookies. We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

About Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.

Cookies may be either ‘persistent’ cookies or ‘session’ cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

The key piece of legislation in the UK relating to cookies is the Privacy and Electronic Communications (EC Directive) Regulations 2003. This cookies policy will also help you to comply with the Data Protection Act 1998 insofar as it affects the use of web cookies.

Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) provides that:

1. Subject to paragraph (4), a person shall not store or gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.
2. The requirements are that the subscriber or user of that terminal equipment – (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent.
3. Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.
4. Paragraph (1) shall not apply to the technical storage of, or access to, information – (a) for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network; or (b) where such storage or access is strictly necessary for the provision of an information society service requested by the subscriber or user.”

This cookies policy should be used in conjunction with or as a part of a full Stairways privacy policy.

The inclusion of this statement in your privacy policy will not necessarily satisfy the requirements of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as regards consent to the use of cookies. Guidance concerning methods of obtaining such consent is included on the Information Commissioner’s website (http://www.ico.gov.uk).

How we use cookies

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

We may use the information we obtain from your use of our cookies for the following purposes:

• To recognise your computer when you visit our website;
• To track you as you navigate our website, and to enable the use of the [specify feature – e.g. shopping cart] on our website;
• To improve the website’s usability;
• To analyse the use of our website;
• In the administration of this website;
• To prevent fraud and improve the security of the website;
• To personalise our website for you, including targeting advertisements which may be of particular interest to you.

Third-party cookies

When you use our website, you may also be sent third party cookies.

Our [advertisers/service providers] may send you cookies. They may use the information they obtain from your use of their cookies:

• To track your browser across multiple websites;
• To build a profile of your web surfing;
• To target advertisements which may be of particular interest to you.

In addition, we use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

Our advertising services providers may send you cookies for the purpose of enabling the service of advertisements based on your previous visits to our website.

Cookie preferences

You can manage your preferences relating to the use of cookies by visiting the preferences in your web browser.

Blocking cookies

Most browsers allow you to refuse to accept cookies. For example:

• In Internet Explorer you can refuse all cookies by clicking ‘Tools’, ‘Internet Options’, ‘Privacy’, and selecting ‘Block all cookies’ using the sliding selector;
• In Firefox you can block all cookies by clicking ‘Tools’, ‘Options’, and un-checking ‘Accept cookies from sites’ in the ‘Privacy’ box.

Blocking all cookies will, however, have a negative impact upon the usability of many websites. [If you block cookies, you will not be able to use the many features on this website.

Deleting cookies

You can also delete cookies already stored on your computer:

• In Internet Explorer, you must manually delete cookie files you can find instructions for doing so at http://support.microsoft.com/kb/278835;
• In Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you ‘clear private data’ this setting can be changed by clicking ‘Tools’, ‘Options’ and ‘Settings’ in the ‘Private Data’ box and then clicking ‘Clear private data’ in the ‘Tools’ menu.

Security:

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorised alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

Grievance:

If you have any queries or concerns about the processing of your information that is available with us, you may email us at ????@????.??.??. We will address your concerns in accordance with applicable law.