The Privacy Policy below discloses our practices regarding information collection and usage solely for the web site located at (the “Web Site”).
By using or accessing the Web Site, you signify your agreement to be bound by our Privacy Policy. If you do not agree to this Privacy Policy then you may not access or otherwise use this Web Site.
Personally Identifiable Information
International Elite 100 does not collect personally identifiable information about you unless you voluntarily submit that information to us through one of our contact pages, by e-mail or other means. The personally identifiable information which you may provide to us could include your name, email address and telephone number.
Non-Personal or Aggregate Information
When you visit the Web Site, we may automatically collect certain non-identifying information about you, such as the type of browser or computer operating system you use or the domain name of the web site from which you linked to us.
Information Usage
We will only use your personally identifiable information as described below, unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you:
inquires or to provide you with the services that you have requested.
Non-personal or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you.
Cookies
We may store some information on your computer’s hard drive as a “cookie” or similar type of file. We use this information internally, to help us enhance the efficiency and usefulness of the Web Site and to improve customer service. “Cookies” are pieces of information that may be placed on your computer by a web site for the purpose of facilitating and enhancing your communication and interaction with that web site. We may use cookies to customise your visit to the Web Site and for other purposes to make your visit more convenient or to enable us to enhance our service. You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences.
Security
The security of your information is very important to us. We attempt to provide for the secure storage of your information by utilising generally accepted industry practices. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and International Elite 100 or information stored on the Web Site or our servers will be free from unauthorised access by third parties such as hackers and your use of the Web Site demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those personnel who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information.
Third-Party Web Sites
As a convenience to you, we may provide links to third party web sites from within the Web Site. We are not responsible for the privacy practices or content of these third party sites, and by providing a link we are not endorsing or promoting such third party sites. When you link away from our Web Site, you do so at your own risk.
Social Media Platforms
The Web Site may contain links to our presence on various social media platforms. We do not operate or control such platforms. You should be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties.
Communications with International Elite 100
Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and nonproprietary. Except to the extent expressly covered by this policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting.
Protection for Children
We do not seek to collect personally identifiable information from children under the age of 13. When we become aware that personal information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.
Privacy Policy Changes
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personally identifiable information in a way that materially differs from this Privacy Policy, including sharing such information with third parties, we will inform you of such changes and provide you the opportunity to opt-out of such differing uses. Your continued use of the Web Site following the posting of any changes to this policy means you accept such changes.
Terms and Conditions
This Privacy Policy and the use of the Web Site is subject to our Terms & Conditions.
Effective Date
This Privacy Policy was last updated on February 1st, 2022.
Our details
This website is owned and operated by International Elite 100 .
We are registered in England and Wales under registration number No. 13900937, and our registered office is at: International Elite 100, 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ
DATA / GDPR
These International Elite 100 Data Processing Terms ( “Data Processing Terms”) apply when International Elite 100 and Customer have entered into a Processing Contract that incorporates these terms by reference. Any capitalized terms are either defined herein or have been defined in other applicable International Elite 100 terms or policies.
1. Agreement to Process
These Data Processing Terms supplement the Processing Contract and any other agreements and agreed-upon terms or policies between the parties. Collectively, these documents reflect the parties’ agreement to the processing or subprocessing (hereinafter referred to simply as "processing") of Personal Data in connection with the GDPR.
2. Duration of these Data Processing Terms
These Data Processing Terms will take effect on the date Customer executes the Processing Contract and remain in effect until, and automatically expire upon, deletion of all Personal Data by International Elite 100 as described in these Data Processing Terms.
3. Application of these Data Processing Terms
3.1 Application of GDPR. These Data Processing Terms will only apply to the extent that the GDPR applies to the processing of Personal Data, including if:
3.2 Application to Processor Services. These Data Processing Terms will only apply to the processor services identified in the Processing Contract and its attachments ("Processing Services").
4. Processing of Data
4.1 Roles and Regulatory Compliance; Authorization.
4.1.1 Processor and Controller Responsibilities. The parties acknowledge and agree that:
4.1.2 Consent from Data Subject. Customer warrants that it has obtained and maintained any required consents necessary to permit the processing by International Elite 100 of Personal Data relating to End Readers.
4.1.3 Authorization by Third Party Controller. If Customer is a processor, Customer warrants to International Elite 100 that Customer’s instructions and actions with respect to Personal Data, including its appointment of International Elite 100 as another processor, have been authorised by the relevant controller
4.2 Customer’s Instructions. By entering into these Data Processing Terms, Customer instructs
International Elite 100 to process Personal Data only in accordance with applicable law: (a) to provide the Processor Services and any related technical support; (b) as further specified via Customer’s use of the Processor Services (including in the settings and other functionality of the Processor Services) and any related technical support; (c) as documented in the Processing Contract, these Data Processing Terms, or any other agreement between the parties; and (d) as further documented in any other written instructions given by Customer and acknowledged by International Elite 100 as constituting instructions for purposes of these Data Processing Terms.
4.3 International Elite 100 Compliance with Instructions. International Elite 100 will comply with the instructions described in Section 4.2 (Customer’s Instructions) (including with regard to data transfers). However, if International Elite 100 believes an instruction infringes the GDPR or other Union or Members State data protection provisions, International Elite 100 will immediately notify Customer (unless that law prohibits International Elite 100 from doing so on important grounds of public interest).
5. Data Deletion
5.1 Deletion During Term
5.1.1 Processor Services With Deletion Functionality. During the Term, if:
5.1.2 Processor Services Without Deletion Functionality. If the functionality of the International Elite 100 interface associated with the Processor Services does not include the option for Customer to delete Personal Data, then International Elite 100 will comply with:
International Elite 100 may charge a fee (based on International Elite 100reasonable costs) for any data deletion under Section 5.1.2(a). International Elite 100 will provide Customer with further details of any applicable fee, and the basis of its calculation, in advance of any such data deletion.
5.2 Deletion on Term Expiration. On expiration of the Term and discontinuation of the processing services, International Elite 100 will, at the choice of Customer, either delete or return all Personal Data (including existing copies) from International Elite 100 systems in accordance with applicable law. Given the nature of the Services, Customer is responsible for informing International Elite 100when it has discontinued the processing services, triggering this clause. International Elite 100 will comply with this instruction as soon as reasonably practicable and within a maximum period of 180 days, unless EU or EU Member State law requires storage.
5.3 Requests from End Readers. International Elite 100 will promptly forward to Customer any requests received from End Readers relating to the deletion or modification of relevant Personal Data.
6. Data Security
6.1 International Elite 100 Security Measures and Assistance.
6.1.1 International Elite 100 Security Measures. International Elite 100 will implement and maintain technical and organizational measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access as described in the Security Measures. The Security Measures include measures: (a) to help ensure the ongoing confidentiality, integrity, availability, and resilience of International Elite 100 systems and services; (b) to help restore timely access to personal data following an incident; and (c) for regular testing of effectiveness. International Elite 100 may update or modify the Security Measures from time to time, provided that such updates and modifications do not result in the degradation of the overall security of the Processor Services.
6.1.2 Security Compliance by International Elite 100 Staff. International Elite 100 will take appropriate steps to ensure compliance with the Security Measures by its employees, contractors, and Subprocessors to the extent applicable to their scope of performance, including ensuring that all persons authorized to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.
6.1.3 International Elite 100 Security Assistance. Customer agrees that International Elite 100 will (taking into account the nature of the processing of Personal Data and the information available to International Elite 100) assist Customer in ensuring compliance with any obligations of Customer in respect of security of personal data and personal data breaches, including (if applicable) Customer’s obligations pursuant to Articles 32 to 34 (inclusive) of the GDPR, by:
6.2 Data Incidents.
6.2.1 Incident Notification. If International Elite 100 becomes aware of a Data Incident, International Elite 100 will notify Customer in accordance with Section 9 of its Security Measures.
6.2.2 Delivery of Notification. International Elite 100 will deliver its notification of any Data Incident to the notification email address provided by Customer or, at International Elite 100 discretion (including if Customer has not provided a notification email address), by other direct communication (for example, by phone call or an in-person meeting).
6.3 Customer’s Security Responsibilities and Assessment.
6.3.1 Customer’s Security Responsibilities. Customer agrees that, without prejudice to International Elite 100 obligations under Sections 6.1 (International Elite 100 Security Measures and Assistance) and 6.2 (Data Incidents):
6.3.2 Customer’s Security Assessment. Customer acknowledges and agrees that (taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing of Personal Data as well as the risks to individuals) the Security Measures implemented and maintained by International Elite 100 as set out in Section 6.1.1 (International Elite 100 Security Measures) provide a level of security appropriate to the risk in respect of Personal Data.
6.4 Reviews and Audits of Compliance.
6.4.1 Customer’s Audit Rights. International Elite 100 will allow Customer or a third party auditor appointed by Customer to conduct audits (including inspections) to verify International Elite 100 compliance with its obligations under these Data Processing Terms in accordance with Section 6.4.2 (Additional Business Terms for Audits). International Elite 100 will contribute to such audits as described in this Section 6.4 (Reviews and Audits of Compliance). As part of any such audit, International Elite 100 will further make available to Customer all information necessary to demonstrate its compliance with the obligations laid down in Article 28 of the GDPR.
6.4.2 Additional Business Terms for Audits.
(a) Customer will send any request for an audit under Section 6.4.1 to International Elite 100 as described in Section 11.1 (Contacting International Elite 100).
(b) Following receipt by International Elite 100 of a request under Section 6.4.2(a), International Elite 100 and Customer will discuss and agree in advance on the reasonable start date, scope and duration of, and security and confidentiality controls applicable to, any audit under Section 6.4.1.
(c) International Elite 100 may charge a fee (based on International Elite 100 reasonable costs) for any audit under Section 6.4.1. International Elite 100 will provide Customer with further details of any applicable fee, and the basis of its calculation, in advance of any such audit. Customer will be responsible for any fees charged by any third party auditor appointed by Customer to execute any such audit.
(d) International Elite 100 may object to any third party auditor appointed by Customer to conduct any audit under Section 6.4.1 if the auditor is, in International Elite 100 reasonable opinion, not suitably qualified or independent, a competitor of International Elite 100 , or otherwise manifestly unsuitable. Any such objection by International Elite 100 will require Customer to appoint another auditor or conduct the audit itself.
(e) Nothing in these Data Processing Terms will require International Elite 100 either to disclose to Customer or its third party auditor, or to allow Customer or its third party auditor to access:
7. Impact Assessments and Consultations
7.1 International Elite 100 Assistance. Customer agrees that International Elite 100 will (taking into account the nature of the processing and the information available to International Elite 100 ) assist Customer in ensuring compliance with any obligations of Customer in respect of data protection impact assessments and prior consultation, including (if applicable) Customer’s obligations pursuant to Articles 35 and 36 of the GDPR, by:
7.2 Reasonable Fee. International Elite 100 may charge a fee (based on International Elite 100 reasonable costs) for any assistance under Section 7.1. International Elite 100 will provide Customer with further details of any applicable fee, and the basis of its calculation, in advance of any such assistance.
8. Data Subject Rights
8.1 Responses to Data Subject Requests. If International Elite 100 receives a request from a data subject in relation to Personal Data, International Elite 100 will advise the data subject to submit his/her request to Customer, and Customer will be responsible for responding to such request.
8.2 International Elite 100 Data Subject Request Assistance. Customer agrees that International Elite 100 will (taking into account the nature of the processing of Personal Data and, if applicable, Article 11 of the GDPR) assist Customer in fulfilling any obligation of Customer to respond to requests by data subjects, including (if applicable) Customer’s obligation to respond to requests for exercising the data subject’s rights laid down in Chapter III of the GDPR, by:
9. Data Transfers
9.1 Data Storage and Processing Facilities. Except for Personal Data covered by International Elite 100 GDPR or EEA-Only Data Processing Addendum addressed in Section 9.2, Customer agrees that International Elite 100 may store and process Personal Data in any country in which International Elite 100 has clients.
9.2 EEA-Only Data Processing. If Customer has executed a International Elite 100 EEA-Only GDPR Data Processing Addendum, certain Personal Data relating to End Readers will be collected, stored, and processed only in the EEA, using International Elite 100 infrastructure and personnel located in the EEA, and avoid an international transfer of End Reader Data.
9.3 Data Center Information. Information about the locations of International Elite 100 Data Centres is available in International Elite 100 Security Measures.
10. Subprocessors
10.1 Consent to Subprocessor Engagement. Customer authorizes International Elite 100 to engage Subprocessors, as generally described in the Security Measures, to assist in processing Personal Data (“Subprocessors”).
10.2 Requirements for Subprocessor Engagement. When engaging any Subprocessor, International Elite 100 will:
10.3 Opportunity to Object to Subprocessor Changes.
11. Contacting International Elite 100 ; Processing Records
11.1 Contacting International Elite 100 . Customer may contact International Elite 100 in relation to the exercise of its rights under the Processing Contract or these Data Processing Terms via the below contact information or via such other means as may be provided by International Elite 100 from time to time.
Registered office address:
International Elite 100
71-75, Shelton Street, Covent Garden, London, WC2H 9JQ
11.2 International Elite 100 Processing Records. Customer acknowledges that International Elite 100 is required under the GDPR to: (a) collect and maintain records of certain information, including the name and contact details of each processor and/or controller on behalf of which International Elite 100 is acting and (if applicable) of such processor’s or controller's local representative and data protection officer; and (b) make such information available to the supervisory authorities. Accordingly, Customer will, where requested and as applicable to Customer, provide such information to International Elite 100 via the user interface of the Processor Services or via such other means as may be provided by International Elite 100 , and will use such user interface or other means to ensure that all information provided is kept accurate and up-to-date.
12. Liability
The total liability of the parties under or in connection with these Data Processing Terms will be subject to the exclusions and limitations of liability in the Agreement.
13. Changes to these Data Processing Terms
13.1 Changes to Data Processing Terms. International Elite 100 may change these Data Processing Terms if the change:
13.2 Notification of Changes. If International Elite 100 intends to change these Data Processing Terms under Section 13.1(c) or (d),International Elite 100 will inform Customer at least 30 days (or such shorter period as may be required to comply with applicable law, applicable regulation, a court order, or guidance issued by a governmental regulator or agency) before the change will take effect by either: (a) sending an email to the notification email address; or (b) alerting Customer via the user interface for the Processor Services. If Customer objects to any such change, Customer may terminate the Processing Contract by giving written notice to International Elite 100 within 90 days of being informed by International Elite 100 of the change.
The General Data Protection Regulation (‘GDPR’) is effective from 25 May 2018.
The General Data Protection Regulation, or “Regulation (EU) 2016/679”, became law on 27 April 2016, but businesses were given just over 2 years to become compliant. Therefore, GDPR will be enforceable as of 25 May 2018.
GDPR applies to processing of data of EU subjects.
Definitions
Data controller means the organisation that determines the purposes for which, and the manner in which any personal data are, or are to be, processed. International Elite 100(‘we’) is the data controller of all personal data used in our business for our own commercial purposes.
Processing of data means any set of operations performed on personal data including collection and storage, and contacting. Data means information stored electronically or in certain paper-based filing systems. Personal data is any data that identifies an individual person, not generic company data.
Approach
In preparation for GDPR, International Elite 100 acknowledges its responsibility to develop and maintain business-wide awareness of the rights of individuals to be empowered and protected in terms of data privacy.
We have consulted broadly and implemented processes, procedures and training to ensure that a legal basis for the processing of personal data underpins all business practices at International Elite 100 .
We recognise that there are some circumstances in which personal data may be processed and that the GDPR clarifies the responsibilities of companies as far as the processing (collection, storage, maintenance and use) of personal data is concerned.
International Elite 100 is actively working on its strategy in relation to data protection, and considers this to be an ongoing endeavour that will continue to be operational beyond the enforcement date of 25 May 2018. We will continually strive to ensure that personal data privacy is embedded as routine practice on a perpetual basis.
International Elite 100 has undertaken to ensure that all staff receive training in the concepts and requirements of data protection law. Staff will be expected to embrace the ethos of data protection law and to adopt practices in the workplace that reflect the company’s commitment to ensuring that the rights of individuals are respected and protected at all times.
International Elite 100 internal policy for data protection requires any products, services or systems adopted by the company (relating in any way to the processing of personal data) to undergo an assessment to establish that they do not contravene the company’s policies to maintain compliance with the GDPR. We also strive to ensure that our suppliers, where relevant (for example, mailing and fulfilment businesses), have appropriate policies in place to safeguard personal data and that the data is transferred securely.
International Elite 100has implemented training and processes to enable staff to recognise and respond to Data Subject Access Requests (‘SARs’). We have also reviewed our current work processes and records in detail, before 25 May 2018, to be sure existing consents meet the GDPR standard.