At ELLTA, we believe in a just world and in nourishing the communities we serve. We are driven by our values of integrity, accountability, passion, humility, simplicity, and achieving results. That’s why we’re also committed to treating your personal information responsibly and making sure that you always know how your information is used.
The purpose of this policy is to inform you how ELLTA Company (“ELLTA”) uses your personal data.
ELLTA uses personal data (information which can identify you) in a number of ways. Whenever we use this data, we try to be as transparent as possible to let you know what we’re doing and why. This data can be gathered and used in a variety of ways, such as when you access our website and your device communicates with our server and provides some information about you with your consent.
We implement security measures to ensure your personal data is kept safe and secure at all times and ensure that no matter where your data is processed, that your rights are respected.
ELLTA Company may transfer your personal data within the ELLTA Company as part of its processing operations. We may also use external data processors in various different countries. If your personal data is transferred and processed elsewhere within the ELLTA Company, or is processed by an external processor, we will make sure that your rights are preserved and that any processing is carried out lawfully and only under our instructions for the stated purpose/s under the terms of a data processing agreement. If your data is transferred out of the EEA, we ensure that such transfers are grounded on EU approved Standard Contractual Clauses.
We are committed to keeping your data safe and secure and have implemented such security tools in our online platforms such as Captchas and Multi-Factor Authentication. In some cases, personal data may be required to implement these measures, however whenever this is required, we will ask your permission and will not retain data obtained for this purpose.
2. Our Websites and Apps
We may process the following types of data in connection with our website or apps:
· Your IP address
· The website you visited prior to landing on our web page
· Time and date of website access
· The pages you visit, time spent, and actions taken on our site
· HTTP code
· Information on the browser and operating system you’re using
This type of personal data is processed on the basis of our legitimate interests for the above purposes and is typically stored for about 7 days. Data we collect may be transferred or processed within the ELLTA Company or by external service processors (i.e. for hosting or content management) in accordance with the above purposes.
If you have enabled geolocation settings on your browser, various services on our websites or other applications may request this information in order to provide you with a service that you request. Any location information will only be used for the purposes that you have requested with your consent.
Cookies may contain information about your device and preferences which is then communicated to our server. While with certain third-party cookies, these may be used to collect information about your browsing history across multiple websites (for which we will always seek your consent beforehand), for cookies which are required for functionality or performance, these will only collect pseudonymized data and will not collect information concerning your browsing preferences.
You can view each type of cookie we use on our website, together with its purpose and how long it’s implemented for in our Cookie Preferences tool.
Strictly Necessary Cookies
These cookies are required in order to display our website correctly and to enable it to function and they cannot be rejected. You can set your browser to reject all cookies using the instructions below, however this will prevent our website from functioning correctly. We process these cookies in our legitimate interest of providing functional online services and they will generally not involve the processing of your personal information.
Functional & Performance Cookies
Upon implementation of functional and performance cookies, we receive the following categories of information concerning your use:
· Number of visits to each page on our website
· Number of subpages accessed
· Time spent on the website
· The order of pages visited
· Your country and city (based on your IP address)
· Movement, clicks and scrolling
We will only implement these cookies with your consent. They are used to enable our website to provide enhanced functionality allows us to measure the use of our website so that we can improve features and performance. The IP address of your computer is automatically made anonymous and will not allow us to draw any conclusions about any individual user. In addition, if you use any of the below browsers, you can follow the below links to find out how to deactivate cookies altogether:
If you use a different type of browser, please consult your browser’s help and support function in order to locate the settings to disable cookies.
NOTE: Blocking cookies may prevent some pages from displaying or functioning correctly.
Targeting and Social Media Cookies
Certain cookies operate to gather information about your usage habits and interests by collecting information about the websites you visit and creating user profiles in order to target advertisements to you based on your interests. These types of cookies are primarily operated by external advertising companies (i.e. Google & Meta), but may be implemented when you visit our site. These cookies will not be implemented on our website unless you specifically consent to their use. You can withdraw your consent at any time by accessing Cookie Preferences .
ELLTA engages with operators of targeting cookies in its advertising activities and is responsible for any data that it processes independently of the cookie operators. The categories of data that are processed when advertising cookies are implemented are as follows:
· IP address
· Individual user IDs assigned by third party advertising companies (i.e. Google & Meta)
· Potential product interests and usage profiles
· Browsing patterns
IP addresses are anonymized in most cases and can generally not be used to locate individuals specifically.
ELLTA uses the following online advertising tools:
Google Ads Remarketing – This is a function of the Google Ads service which allows us to present advertisements to you based on your interests across other websites within Google’s ad network. Cookies are used which monitor user interactions across multiple websites and then builds profiles of user behavior to show advertisements which are personally targeted. These cookies may last up to 180 days.
Google Tag Manager – Implements website tags and may gather certain information such as access time and IP address. No cookies are implemented.
Other Targeting Cookies - Google Analytics
Our website uses Google Analytics. Google Analytics is a web analysis service from Google which provides websites with usage monitoring technology and advertising supports. This is done by using cookies to analyze user activity on our website. This is done by the implementation of a unique cookie on user devices which sends information on your usage to Google’s servers in the USA. Google has implemented various technologies to ensure that your data is kept private and the data stored by it cannot be traced to you personally. For example, IP addresses are masked within the EEA to ensure that except in limited circumstances a full IP address is not stored by Google or transmitted to the USA.
Google uses this information on our behalf to analyze your use of our website in order to compile reports on website activities and provide additional services related to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. Google Analytics is also used to build user profiles based on browsing habits so that advertisements can be targeted or re-targeted to specific users across various sites that have implemented Google advertising technologies.
We use Google Analytics to analyze and regularly improve the usage of our website. We also make use of targeting and re-targeting advertisements to users. Statistics obtained are used by us to improve our online offering and personalize content to our users. In addition, we gain information about the functionality of our site (for example to detect navigation problems). ELLTA may also share any data obtained within the ELLTA Company.
Cookies in relation to Google Analytics will only be implemented with your consent for the above purposes.
You can opt-out of Google Analytics directly with Google. Information on how to do this can be found here . You can also set your browser to entirely reject cookies using information provided above.
Other Targeting Cookies – Adobe Analytics
We have also implemented Adobe Analytics cookies on our website which provides us with analysis and insights into your use of our website similar to other analytics cookies. This technology analyses your interactions across ours and other websites with Adobe Analytics in order to understand your interests and provide more relevant marketing messages to you. As part of this analysis, data in relation to your interactions, device, and IP address is used.
You can opt out of Adobe analytics directly with adobe. Information on how to do this can be found here . You can also set your browser to reject cookies by default using the information provided above.
4. Social Media Plug-ins
We have implemented Social Media Plug-ins on our website. These are programs that are embedded within our website that communicate with and link to social media platforms. If you are logged in to a corresponding social media platform, the plug-in may permit your activities to be attached to your profile.
Social network providers store data collected about you from plug-ins as user profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of their platforms. Through the plug-ins we offer you the possibility to interact with social networks and other users as a convenience to you and in order to optimize your experience on our websites. Data collection operates regardless of whether you are a logged-in user of the relevant social media platform or not, so long as you interact with the plug-in. Data transmitted includes:
· Your IP address
· The address of the website where the plug-in is located
· Details of your device’s browser
· The date and time of your access
· Your social media profile (if you are logged in to the social platform)
Social media platforms may use the above information to build usage profiles and customize their offering and/or advertising to you. Retention and processing of your data in this regard, beyond the initial transmission of data from our website, is not managed by ELLTA. The legal basis for the transmission of your data is based on your consent in interacting with the plug-in.
Where the ELLTA website has integrated various Social Media Plug-ins, reference may be had to their respective privacy policies to understand how they may use your data.
YouTube videos may be integrated into our website. These videos are stored on http://www.YouTube.com and can be played directly from our website. No data about you as a user will be transmitted to YouTube, if you do not click on the videos to start playing them. If you play a video the information described above in this section will be available to Youtube. In addition, if you are logged in to your Google account, any information received by Youtube may be associated with your Google account.
5. Social Media Pages
ELLTA may process personal data in the course of operating its social media pages (i.e. Facebook, Twitter, Instagram etc.). ELLTA uses these platforms in order to promote its brands and engage with consumers. When users interact with ELLTA’s various social media pages/accounts, users’ personal data will primarily be governed by any applicable privacy policies or terms and conditions of the relevant social media platforms and retained in line with the respective platforms’ policies.
Insofar as ELLTA uses your data on its social media pages, we have access to the following information:
· The name on your profile
· Data you post online (i.e. comments, messages, images etc.)
We use the above data in order to communicate with you and manage our social media accounts. This is done based on our legitimate interest of operating our social media accounts and promoting our brands through communicating with consumers.
We may also have access to page statistics provided by social media platforms which gives us insights into the usage and effectiveness of our social media pages. This allows us to evaluate behavior of users who interact with our social media accounts so that we can tailor content to them. The statistics which are visible to us are anonymous and we cannot identify any user from the provision of such information. For further information on how social media platforms process your data, please consult the relevant privacy policies.
6. ELLTA Online Account
Depending on your region, you can sign up to receive the latest news, special offers and exclusive savings on ELLTA's products through the website. Information you provide will be used to communicate with you by various methods in relation to such offers and marketing materials and will not be used for any other purpose. The following information may be processed:
· First and last name
· E-mail address
· Home address (street, city, postcode etc.)
· Phone number
This information will only be processed with your consent and will be held until you indicate that you no longer wish to receive the above-mentioned news, offers, or marketing messages.
In certain circumstances, it may be possible for you to log in to your existing profile on our website using your Facebook social media login credentials. Where this is possible, you will find the corresponding Facebook symbol on the login page. Before you can log in in this fashion, your consent is required for the process and transmission of your information. Should you agree to the transfer of your information through the Facebook login, your information will be transferred to populate the ELLTA registration form. No other data will be transferred, and your ELLTA account will be kept entirely separate from any social media profiles.
In order to perform the authentication process for registration and login, your IP address is transmitted to the respective social network provider. ELLTA has no influence on any processing activity in which this information is used.
7. Customer Service
When you contact us by email, contact form through our website, or by any other means, we will collect certain personal data from you in order to be able to communicate with you and address your questions or concerns. We may also ask you if you wish to receive marketing messages or other product related communications from us. If you agree, your data may be used for these purposes also. This data may include (among any other data you may provide us in the course of our communication with you):
· First and last name
· E-mail address
· Home address (street, city, postcode etc.)
· Phone number
When you contact us, we will generally only process your information based on your consent. In certain circumstances however, we may rely on our obligation to fulfill a contract or our legitimate interests—in particular where you have communicated a quality issue or there is any risk of safety or is required in the context of a legal claim or prospective legal claim. We generally retain information you submit in this fashion for up to 1 year. Data will be retained longer if it is required for the above-mentioned purposes (i.e. quality issues or risk of legal claims).
Where you contact us by phone, calls may be recorded. This is done for training and quality assurance purposes with your consent. You will be informed of the operation of call recording prior to any recording taking place. Recordings may be retained for up to 90 days.
8. Promotions, Competitions, & Other Marketing Activities
From time to time we may run particular promotions or competitions which involve you providing us with your personal data. Where this is necessary for a promotion or competition, we will always provide you with information on how your data is processed for that campaign. In such circumstances, your information will usually be processed only with your consent, except if your are a competition winner in which case we may rely on a different legal basis to process your data. In certain circumstances, it may be a term of any competition that a winner will agree to an element of publicity (i.e. in announcing the winner on social media platforms). Data held by ELLTA for the purpose of administering promotions or competitions may be kept for up to 200 days after the expiry of the relevant campaign. Data of competition winners may be kept for longer. Further information in relation to how we may use your data in specific promotions or competitions may be found in the corresponding applicable terms and conditions.
Whenever we collect personal data in connection with promotions or other marketing activities, we may seek your consent to provide you with further information and marketing materials in relation to ELLTA products. Where you consent to our use of your data for this purpose, we may combine this data with other data in relation to you which we hold for the same purpose. We may also use service providers to combine it with other data they may hold (i.e. from social media or cookies based data) to build demographic or interest-based profiles in order to target advertising to sections of various markets. We may use these targeting technologies and services to aid in our marketing activities and provide you with information on our products which may be most relevant to you.
9. Direct Marketing
ELLTA will only provide you with direct marketing communications where you have specifically requested or consented to receive them (such as when you have subscribed to receive such communications through a ELLTA online account). We may also on occasion offer to send select consumers, business partners, or testers individual product information, offers, news, and/or samples by post. This is to promote new or existing product and to gain insights into the marketplace.
Any personal data we hold in relation to you that we use for direct marketing will be deleted when you unsubscribe from our mailing list.
10. Business Partner Privacy
ELLTA Company is committed to privacy and safeguarding personal data we may process in the context of business relationship and transactions with our valued business partners.
We may process the following categories of data in the course of our business relationships:
· E-mail address
· Phone number
· Details on any commercial registers
· Business address
· Business payment information
· Credit information
· Purchase order information
· Photos / video recordings
The above data may be used in ELLTA's business relationships in order to facilitate communication with our partners. Primarily data held in relation to these relationships will not constitute personal data as defined in applicable data protection law, however personal data in relation to points of contact and other staff of our business partners may be incidentally processed. This type of data is primarily processed in ELLTA’s legitimate interest of maintaining relationships, services, and communications with its business partners. In addition, ELLTA relied on the basis that it is legally required to process such data (i.e. for tax or anti-money laundering purposes).
ELLTA will ensure that personal data acquired and processed as part of its business relationships is only handled by staff members who are required to have access to it for the purposes of the processing activities and that it is kept safe and secure at all times. ELLTA will retain any such data for up to 7 years after the expiry of contractual relations and in any event in accordance with any legally applicable retention times.
11. Surveys, Market Research & Product Testing
From time to time ELLTA may operate voluntary surveys, market research or product testing campaigns. Personal data may be processed in the administration of such activities and will only be processed with the consent of participants. Categories of data processed may include:
· E-mail address
· Phone number
· Other socio-demographic information
In some campaigns, it may be possible to participate anonymously, however in some cases you consent to such processing is a pre-requisite for participation. This data will be deleted/anonymized after the conclusion of the relevant campaign. Further information in relation to specific campaigns will be available in applicable terms and conditions.
12. Your Rights
Where we are processing your data based on your consent, you have the right to revoke your consent at any time. Any data we continue to hold on this basis will then be deleted.
You also have the following rights:
o The right to access your personal data held by us
o The right to the erasure of your data in certain circumstances
o The right to have any data we hold rectified if it is incorrect
o The right to apply for a restriction of the processing of your data in certain circumstances
o The right to object to the processing of your data in certain circumstances
o The right to data portability of your data
You also have the right to lodge a complaint with the data protection supervisory authority. Please note that the lead supervisory authority with respect to ELLTA is the Data Protection Commission in Ireland.
Where you request access to your personal data held by ELLTA, we may seek some further information from you in relation to your request, including a requirement to provide proof of identity and entitlement to request access. We will endeavor to process any such requests as soon as possible and in any event within one month. Should it be required to extend this time, we will let you know in advance.
Where you request that we delete your data, we may seek further information from you in relation to your request, including proof of your identity and entitlement to request such erasure. We will comply with such requests in the following circumstances:
· Where the personal data is no longer necessary for the purpose it was collected
· Where you revoke your consent to data processed solely on this basis
· Where you have objected to processing in circumstances where we rely on our legitimate interest and no compelling legitimate grounds exist to continue processing activities
· Your data has been unlawfully processed
· Erasure is required to fulfil a legal obligation
Where data held by us contains errors or is otherwise incorrect, you have the right to request that it be correct. In certain circumstances you may also have the right to supplement it with further information that you wish to provide.
Restriction of Processing
You have the right to apply to us for a restriction of processing in the following circumstances:
· Where you dispute the correctness of the data held by us
· Where the processing is unlawful
· The data is no longer required by the controller but is required by you for the exercise or defense of a legal claim
· You have raised an objection to processing where it is not certain whether the legitimate grounds relied upon by the controller override your objection
Right to Object to Processing
You may object to the processing of your data in circumstances where it is being processed by us under our legitimate interest where you have particular grounds for such objection. Any such objection shall be assessed based on the existence any potential compelling legitimate grounds to continue the processing in the circumstances.
Attn: Consumer Affairs – Privacy Office
PO BOX 66117
Albuquerque, NM 87193-6117, USA