The Elian Group (which, for the purposes of this Privacy Statement, includes Elian (Middle East) B.S.C.(c).) is committed to protecting and respecting your privacy.  We are aware of the concern which exists over the security of information which you provide to us (both over the internet and otherwise).  The following statement gives an explanation of what we do with any information provided by our users and clients.

For the purposes of this statement, Information includes:

  1. all the details we hold about you and the matters (if any) upon which we are instructed;
  2. all personal data, if any, about you and your officers, employees, associates and, where applicable, family members; and
  3. all sensitive personal data (e.g. data about health or ethnic origin), if any, about you and your officers, employees, associates and, where applicable, family members.

If you wish to communicate with us about our processing of your personal data you may contact us via email at jsy@elian.com or by post at 44 Esplanade, St Helier, Jersey, JE4 9WG (Attention: Group In House Counsel).

Use of your information

We reserve the right to monitor and store Information relating to who visits our website(s) principally so that we can ensure our website is easy to use and identify any areas for improvement.

We may also use and disclose Information for any reasonable purpose including but not limited to the following:

(a)        undertaking appropriate anti money laundering checks (including without limitation the disclosure of Information to a credit reference or fraud prevention agency, which itself may retain a record of the information disclosed to it);

(b)        undertaking internal conflict-of-interest checks, analysing our performance, and generating internal financial and marketing reports;

(c)        assessing legal and financial risks, and collecting debts;

(d)        providing your Information to third party service providers that provide services to us;

e)        providing your Information to anyone who takes over our business or business assets or with whom we merge;

f)        providing your Information to the police, any law enforcement agency or other person, as we consider appropriate, to assist in the identification and location of anyone who may have committed an unlawful or illegal act;

g)        providing your Information to any court, tribunal or regulator (including without limitation in order to comply with laws, regulations or court orders in any jurisdiction, whether or not the same is strictly binding or capable of being enforced against us);

h)        providing your Information to any other person where disclosure is made at your request or with your consent;

i)        marketing our services to you in the future, which may involve contacting you or, where applicable, individuals within your organisation using the contact details that you have provided to us. and

j)        for any other reason as required or permitted by applicable law.

Whenever you visit our website(s) and/or provide us with Information, you are consenting to our collecting and using that Information in accordance with this Privacy Statement.

Disclosure

Please be aware that the Elian Group has offices in various jurisdictions and any Information that you provide through our website(s) (or otherwise) may be transferred to and shared with entities within each group that are based in our various locations (including countries outside the European Economic Area) and some of these jurisdictions may not provide the same level of protection for personal data that is provided by your own country.

The Elian Group may also use third party service providers based in various jurisdictions (including countries outside the European Economic Area) and any Information that you provide through our website(s) (or otherwise) may be transferred to and shared with service providers that are based in jurisdictions which may not provide the same level of personal protection for personal data that is provided in your own country.

If your Information is posted to a service on our website(s), it may be accessed and used by users of that service from anywhere in the world.

This Privacy Statement applies only to our website(s). The Elian Group does not control and is not responsible for the privacy policy of any website or organisation to which our website(s) provide links.  By including references, hyperlinks or other connections to such third party websites we do not imply any endorsement of them or any association with their owners or operators.

Whilst we do our best to safeguard your Information we cannot ensure or warrant the security of any Information that you may transmit to us.

Accessing and updating

You are entitled to see the Information held about you and if you wish to see such Information, you may contact us at jsy@elian.com and address your request to the Group In House Counsel.  We are entitled by law to charge you a fee of up to GBP 10 to meet our costs in providing you with details of the information we hold about you.

If you deem any Information we hold on you to be inaccurate, you should inform us of this and we will ensure that the relevant Information is promptly corrected.  In addition, if you can demonstrate to us that we do not have a legitimate reason for keeping personal information on you, then we will immediately erase such information from our systems.

To dispute any of the Information we hold on you may contact us at jsy@elian.com and address your request to the Group In House Counsel.

Extent of data being processed

No personal information is collected about general visitors to our website.  However, your browser supplies some basic information about your visit.  The collection of this information is common practice and is used to analyse and understand how the website is being used.  The following information is logged: IP address (the internet address of your computer), date and time of your visit, the type of computer, browser and operating system you are using, the URL’s of websites that referred you to the website and the path you take through the website.

Right to refuse cookies

Cookies are small pieces of information which are stored on your computer by your web browser. They are used by almost every website to improve your online experience.

We may store cookies on your computer to give you access to certain parts of our website(s) and to let us know how you are using our website(s). This allows us to recognise users and their preferred settings and avoids users having to re-enter information when they visit our website(s) in the future.

Unless you have set your browser so that it will decline cookies, our system may set some cookies as soon as you visit our website(s). You can block cookies by setting your browser to refuse all or some cookies or to alert you to when a cookie is being sent. For information about this you should look in your browser’s “help” facility. If you have previously browsed or used our website(s) and no longer wish to accept cookies, you should be aware that some cookies will have been set. You may delete these cookies at any time by following the instructions that can be found on allaboutcookies.org. Some of the cookies we use are essential if our website(s) is to operate properly. If you decline them, some of the features of our website(s) may not work as well as we intend and you may not be able to access or use some features or services.