Elisyan Wealth Privacy Policy

Elisyan Wealth is Private by Design

Introduction

This Privacy Policy applies to the websites owned and operated (“Website”) by Elisyan Wealth Ventures Ltd, doing business as Elisyan Wealth (Elisyan, We, Us, or Our). This Privacy Policy describes how Elisyan collects and uses the personal data collected through the Website and Services located behind the logins of Elisyan Applications. It also describes individual rights regarding the use of, access to, and how to update, correct, or remove personal information. The use of information collected through Our Services shall be limited to the purpose of providing the Service for which Elisyan is engaged.

If you have questions or complaints regarding this Privacy Policy or Our practices, please contact Us via email at dpo@elisyanwealth.com.

Your privacy is important to us and we respect each individual’s right to privacy. This privacy policy explains the personal data that Elisyan collects and processes, how it processes data and for what purposes it is collected and processed. This Privacy Policy further describes our commitment to preserving the privacy and security of your personal data. We will collect and use information through Our Website only in the ways disclosed in this Privacy Policy. We have created this Privacy Policy to let you know what information we collect when you visit Our Site, why we collect it, and how it is used. By using this website, you consent to the data practices prescribed in this Privacy Policy.

Who We Are and Our Commitment to Privacy

Elisyan Wealth Ventures Ltd is a company located at 30 Webster Road, London, England. At Elisyan, we believe that the less information we know about you, the better. After all, it is impossible to lose, misuse, or abuse information we don’t have. To the extent that we have control over your data or data about you, we see ourselves as custodians of that data on your behalf.

We use your data solely to provide you with Services in which you enrol and to provide you an enhanced user experience when you visit our Website. Our business is providing Elisyan products and Services to you, the customer. We have no desire or interest to use or transfer the limited data we acquire for any other purposes.

Who are You

Unless otherwise noted, we refer to you, the Customer, as an owner of an individual account.

Information Collected Through the Elisyan Services

We collect some data from you, in order to provide you with our Elisyan products and Services, in addition to your use of our Website. You provide some data directly, such as when you create an Elisyan account or contact us for support. Such data is limited to your email address only. We get some limited data from your use of the Elisyan products and services. Such data includes your IP address, and the make and model of your device through which you access or use Elisyan products or services.

We use your personal data to provide you with services associated with the use of your Elisyan account and to provide you with a rich customer experience through our customer support. In particular, we use your data to provide Elisyan services, which includes updating, securing and troubleshooting, and providing support.

The following is a more detailed description of the types of Elisyan account user data:

We process two kinds of user data to deliver our services: (i) Secure Data and (ii) Service Data. Both are treated securely with respect for customer privacy and data confidentiality, but there are important technical and usage differences.

(i) Secure Data

Secure Data are the data that we are not capable of decrypting under any circumstance. It includes all information stored within Elisyan accounts. These data are encrypted using secure cryptographic keys that exist only in the possession and under the control of our customers. We have no way of accessing or providing decrypted Secure Data, and we never receive copies of unencrypted Secure Data.

Your Secure Data is your property. We claim no rights to it beyond those necessary to deliver services to you. You may add, modify, and delete Secure Data at your discretion. If you do not have an Elisyan account, you cannot provide us with Secure Data.

(ii) Service Data

We inevitably acquire Service Data about your usage of Elisyan, your account, and your payments through operating our services. We retain only enough Service Data to operate and maintain the services. These data are never used for any other purpose.

Service Data are kept confidential. It is visible to Us and includes, but is not limited to, server logs, billing information, client IP addresses, number of connections, number of items, and email addresses. Service data includes the name you provide us for your profile and any image that you may upload, at your option and discretion, as part of your profile.

If you are using our services, we retain the right to hold and use Service Data to provide our services, troubleshoot problems, analyse the performance, and demands on our services, and to provide our payment processors with the information they need to process payments.

(iii) Diagnostic Data (Optional)

Diagnostic Data are a category of Service Data which are not automatically collected or required for operation of our services.

In some cases, we seek diagnostic reports and other troubleshooting, bug, and crash reports from customers to help identify and solve problems with our products and services. This information is sent to us only on a case by case basis, or by users who explicitly opt into our beta software programs or who otherwise explicitly choose to provide diagnostic data to us.

Diagnostic Data may contain sensitive information about your devices and operating environment as well as personally identifying information. Although there may be occasions when we ask for Diagnostic Data to assist you with a problem, you are never obligated to provide it.

Diagnostic data never includes decrypted Secure Data. We will never ask for your Account Password or Secret Key.

Keeping Your Information Safe

We understand and accept our responsibility to protect Service Data and Secure Data. We use strict access control mechanisms, network isolation, and encryption to ensure that Secure and Service Data is only available to authorised personnel. Additionally, Secure Data cannot be decrypted even by those who do have access to it.

Information Collected from Your Use of Our Website

In a few areas on Our Website, We ask you to provide personal information that will enable Us to enhance your site visit, to assist you with technical support issues or to follow up with you after your visit. It is completely optional for you to participate. For example, We request information from you when you:

Subscribe to a newsletter.
Participate in promotional offers.

Elisyan uses your information for specific purposes. Your information may be used to:

Send you requested information about Elisyan.
Provide support.
Market Elisyan products or Services to you.
Provide you with access to Elisyan Services.

Personal information you provide will be kept confidential and used to support your customer relationship with Our company.

All email communication with you will be on an Opt-In basis. This is solely at your discretion. Occasionally, We will send you e-mail communications with information, which may be useful to you, including information about Our products and Services or about offerings from affiliates or business partners. When you first provide Us with your e-mail address, you will be given the option of not receiving any such e-mail communications. We will include instructions in Our e-mail messages on how to unsubscribe if you later decide you do not want to receive any future e-mail communications. At any time, you can easily opt-out of receiving further marketing from Elisyan by contacting Us at the address below and requesting to have your name removed from Our lists.

Information Sharing and Disclosure to Third Parties

Agents or contractors of Elisyan may have access to your personal information for the purpose of performing services on behalf of Elisyan. All such agents or contractors who have access to your personal information have Data Processing and Confidentiality obligations to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for Elisyan.

Unless We tell you otherwise, or unless otherwise stated in this Privacy Policy or required by law, We do NOT sell or rent your personal information to any third parties. However, We might share your personal information with Our service providers, such as Our hosting services providers. If you choose to participate in a survey, a focus group etc., we may also share de-identified data with Our customers.

Information collected from you is only used to complete and support your purchases from Elisyan and use of the Website and to comply with any requirements of law. Elisyan may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on Elisyan or this Website; (2) protect and defend the rights or property of Elisyan; or (3) act in urgent circumstances to protect the personal safety of users of Elisyan, its web sites or the public. We may collect and possibly share your information to investigate, prevent, or act regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Our terms and conditions posted on Our Websites, or as otherwise required by law.

If Elisyan is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on Our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. We may also disclose your personal information to any other third-party with your prior consent.

Compliance with the laws

Elisyan fully complies with the United Kingdom’s privacy laws and the GDPR.

Data Location and Transfer

Elisyan data are held on servers located within the UK and EEA.

Customer support system

Our customer support and email services are hosted in the UK and EEA.

Third-Party Data Processors

Your Secure and Service data are held by third-party data processors, who provide us with hosting and other infrastructure services. The locations of these are described above. In many cases (but we cannot promise that this will always be the case) even Service data held by these entities is encrypted with keys held only by us.

Contacting You

We may use your contact information, that is, the contact email address provided by you, to communicate with you about Service activity, provide support, and send you other information such as product updates and announcements. You may choose to stop receiving communications from us, except certain important notifications such as billing and account security alerts.

Your Responsibilities for Protecting Your Data

When you create an Elisyan account you will receive a Secret Key and will be prompted to create an Account Password. Your Secret Key is generated on your device and your Account Password is something you create yourself. For your protection, you should create a strong and unique Account Password to ensure that it is not easily guessed.

It is extremely important that you understand that anyone with both your Secret Key and Account Password can access your Secure Data. It is equally important that you keep a copy in a safe place for your own reference, because future access to your Secure Data depends on having access to both your Secret Key and your Account Password. We will never ask you for your Account Password or your full Secret Key, and you should never send it to us or anyone.

Due to the nature of our design and the sensitivity of the information you entrust to us (even in encrypted form), it may not be possible for us to help you with certain customer service requests unless you are listed as an account owner and are communicating from your verified email address. If you change your email address, it is very important that you update your email on your Elisyan account(s) or you may eventually lose access.

Data Protection Principles that We Practice

(i) Data Portability

We want happy customers, not trapped ones. We will not lock you out of your own data. However, we are unable to decrypt your Secure Data; you will need your Account Password and Secret Key to decrypt it.

You may export your Elisyan data at any time you wish during the life of your account. If you discontinue payment, your account will enter a frozen (read-only) state for a period not less than six months during which you may still retrieve and export your data.

Export is limited to your Secure Data.

(ii) Your Right to Know to What We Know

You have the right to know what we know about you and to see how that data is handled. You may request a screenshot of what we can see about you in our back-office systems. However, to protect customer privacy, such requests must be carefully authenticated beyond demonstrating control of the customer’s email address.

(iii) Your Right to Have Your Data Erased

As we are merely custodians of your data, account owners have the right to instruct us to remove data permanently from our systems. To ensure that no one’s data is deleted without their consent, you must first delete your account through an authenticated session. After your account has been deleted, the account owner may contact us and ask for the data to be expunged. Once the request is authenticated, the data will be removed from our active systems within 72 hours.

Disaster recovery and data availability requirements mean that Elisyan has a legitimate interest in maintaining secure and immutable backups. Backups are kept for 30 days. Erasure requests will leave those backups untouched, and we will only remove data from backups if legally compelled to.

(iv) Your right to access and control your personal data

You can also make choices about collection and use of your data by Elisyan. You can control your personal data and exercise your data protection rights by contacting Elisyan at the address and information provided below. You can add, remove, edit, change any data that are in the Elisyan Application.

Cookies and Tracking

We do set and use cookies (small text files placed on your device) on our own domains and subdomains to store settings that assist with identifying your account for sign-in. We also use third-party packages and trackers for our public pages that may set cookies on your computer. These cookies are used to understand broad and anonymous user behaviour when you visit our Website. Such user behaviour includes time spent by a visitor on the website, most visited webpage, aggregated clicks on signups, etc. We also use these third-party cookies to serve more relevant advertisements to visitors once they have left the Elisyan website on our partner sites across the web.

You may disable cookies in your browser and continue to use our services without impact. We do not use third-party trackers in our client applications for Android or iOS.

Client applications, including web browsers, will store information about your account to assist with future sign-ins and keep some information available to you when you are not signed in. Users may remove all such information from their devices, but doing so will require that they provide complete information (account details, Account Password, and Secret Key) on subsequent sign-ins.

Consent for Underage Enrolment

Those under the age of 16 may not use the services without the consent or authorisation of their parent or legal custodian.

Disclosure

We will comply with applicable laws and the contracts with our customers to provide Service Data and encrypted Secure Data to law enforcement agencies. If permitted, we will notify you of such a request and whether or not we have complied. Your Secure Data remains encrypted with keys which we do not possess, and so we can only hand over Secure Data in encrypted form.

Breach Notification

In an event of a breach, we recognise our responsibility to our customers and to the public to disclose the nature of the risk and provide a transparent account of the events without undue delay. We follow applicable requirements under the laws, that is, the United Kingdom’s data privacy breach notification requirements and the requirements related to data breach notification under the GDPR.

Updates to our Privacy Policy

At our discretion, we may make changes to this Policy and note the date of the last revision. You should check here frequently if you need to know of updates to our Privacy Policy. We maintain the right to send you an email informing you of substantive changes. Previous versions will be made available from this page.

If you have any questions about this Policy, you can contact our support team or write us by mail at:

30 Webster Road, London, SE16 4DF, United Kingdom

Supervisory Authority

If you have concerns or complaints about this policy or practices that you do not feel you can resolve through contacting us, you should bring those concerns to your local regulatory authority.