This Platform is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Elen Financial Software Ltd
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.
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.
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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, email address and telephone numbers.
Financial Data includes bank account details, payment card details and information relating to personal finance.
Transaction Data includes details about payments to and from you.
Technical Data includes 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, and other technology on the devices you use to access this Platform.
Profile Data includes your username and password, your preferences, feedback and survey responses.
Usage Data includes information about how you use our Platform and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us 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. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
create an account on our Platform;
subscribe to our service or publications;
request marketing to be sent to you; or
give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as Google Analytics based outside the UK;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the UK
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
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:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new user of the Platform
(a) Identity (b) Contact
Performance of a software as a service agreement relating to the provision of a financial adviser digital back office platform
To process and deliver your order (if applicable) including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
(a) Performance of a software as a service agreement relating to the provision of a financial adviser digital back office platform (b) Necessary for our legitimate interests (to recover debts due to us)
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a software as a service agreement relating to the provision of a financial adviser digital back office platform (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers or Platform users use our products/services)
To administer and protect our business and this Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Necessary for our legitimate interests (to study how users or customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of users or customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
To enable us to integrate third party software with our Platform, we may share your data with the following specific third parties: Transact Nucleus; P1; Quilter; and CashCalc,
(a) Identity (b) Contact (c) Profile (d) Usage (f) Technical
(a) Performance of a software as a service agreement relating to the provision of a financial adviser digital back office platform (b) Necessary to integrate third party software with the Platform and making third party applications available to users of the Platform
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
5. Disclosures of your personal data. We may share your personal data with the parties set out below for the purposes set out in the table above.
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.
External Third Parties as set out in the Glossary.
Specific third parties listed in the table.
6. International transfers. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security. 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our 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 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 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.
By law we have to keep basic information about our customers (who, for the avoidance of doubt, are companies that have entered into a separate software as a service agreement with us relating to the provision of the Platform as a service) including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
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. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please email email@example.com.
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. LAWFUL BASIS. 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.
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.
External Third Parties
Gmail and Outlook Integration
If you use the Gmail or Outlook integration, you will be asked to give our Platform access to information from your Google or Microsoft account. Our Platform will be able to read emails from your connected Google/Microsoft account. Our Platform will scan the content of your emails in order to provide you with the automatic email logging feature. The Platform will store the following information: message ID, thread ID, time a message was sent or received, participants' names and emails (for Bcc, Cc, From and To), subject of the mail, body of the mail, attachment data (ID, type, size and file name) of all emails exchanged with clients on your account on the Platform. You understand that the correspondences tracked this way will be visible to other users with access to your company domain.
You can learn more about how we access this data here:
Set up your email integration
YOUR LEGAL RIGHTS
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.
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:
Request the transfer of your personal data 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.
Service providers acting as processors based in inside and outside the UK who provide IT or system administration services.
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
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.