Privacy Policy
Our website address is: www.elusas.com.
Owner and Data Controller
Elusas Services Limited
167 Leontiou A’ Street,
Hawaii Kamelia Court,
5th floor
3022 Limassol
Cyprus
The purpose of this Policy is to define the basic principles by which the Company processes the personal data of customers, suppliers, business partners, employees, and other individuals and indicates the responsibilities of its business departments and employees while processing personal data.
What personal data we collect and why we collect it
We collect personal information that is required as a consequence of our contractual relationship with you, to enable us to carry out our contractual obligations to you. Failure to provide this information may prevent or delay the fulfilment of these obligations.
The categories of Personal Data we collect or obtain may include without limitation:
1) Personal Details: Name, social insurance number, tax identification number, ID number, passport number, age, date of birth
2) Contact Details: Address; Telephone Number; Email Address and Social Media Profile Details
3) Employment Details: Industry; Role; Business Activities; Names of current and former employers; Work Address; Work Telephone Number; Work Email Address; and Work-related Social Media Profile Details
4) Education History: Details of your Education and Qualification
Contact forms
The users of this Document are all employees, permanent or temporary, and all contractors working on behalf of the Company.
The Company may be a data processor or data controller; this will depend on the circumstances in which personal information is collected, held or used.
How we use your personal information and the basis on which we use it
We use personal information to:
- carry out background checks prior to accepting you as a client;
- contact you with questions and other information regarding the services we are providing to you;
- ensure that our records are kept accurate and up to date where you, your employees or contractors work on or visit our facilities;
- ensure we issue accurate invoices for our services;
- send you messages about products and services which we think will be of interest to you;
- comply with legal obligations to which we are subject
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
- to fulfil our contractual obligations to you, for example to ensure that invoices are issued correctly, to carry out various outsourced services such as payroll, expatriate immigration services, tax compliance services etc. and for ensuring you are able to access our premises when required;
- to comply with our legal obligations to you or to a third party ( e.g to comply with a court order);
- to meet our legitimate interests so that: we are able to provide the services you request; our services function correctly in relation to your business; any complaints or concerns can be promptly relayed to you; we can respond to any questions or concerns you might have; we may carry out research and analysis to ensure products and services we offer are relevant to you, and; our records are kept up to date and accurate; and
- send you direct electronic marketing messages to the extent you have consented to receiving such messages in accordance with applicable law.
Information Sharing
In general, we do not share your personal information with third parties unless we have a lawful basis for doing so.
We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery and payment processing. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.
Other situations in which we may disclose your personal information to a third party, are:
- where permitted by law, to protect and defend our rights and property;
- to fulfil our contractual obligations to you in respect of the services you have requested us to provide to you for example with regard to various outsourced services; and
- when required by law, and/or public authorities;
Data Retention
We will only keep personal data for as long as necessary for the purposes for which it was collected, or as required by applicable law or regulation.
Unless there are any overriding legal, regulatory or contractual requirements, we will retain records of services provided (which may include personal data) in accordance with our document retention policy.
Information Security
We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. We require all employees and principals to keep personal information confidential and only authorised personnel have access to this information.
What rights you have over your data
Users may exercise certain rights regarding their Data processed by the Owner, as follows:
Withdraw their consent at any time
Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data
Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and amend
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data
Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed
Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint
Users have the right to bring a claim before their competent data protection authority.
How we protect your data
Data Controller: The natural or legal person, public authority, agency or any other body, which alone or jointly with others, determines the purposes and means of the processing of personal data.
Data Processor: A natural or legal person, public authority, agency or any other body which processes personal data on behalf of a Data Controller.
Processing: An operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of the data.
Further information
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.