Privacy Policy

5CL Limited trading as Eleven Advisory (registration number 07089812) of 5 Chancery Lane, Clifford’s Inn, London EC4A 1BL, (we, us, our) is committed to ensuring that your privacy is protected, and all data collected by us will be processed in accordance with this privacy and cookies policy. Please read this policy carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is 5CL trading as Eleven Advisory. We can be contacted at cliff@elevenadvisory.com.

1 WHAT INFORMATION WE PROCESS

1.1          We may collect and process the following information from you:

1.1.1     information about you, including your name and email address, that you give us by filling in the contact form on our website www.elevenadvisory.com (our Website); and

1.1.2     information we may automatically collect such as technical information including the internet protocol (IP) address used to connect to the internet, information about your visit including the full Uniform Resource Locators (URL) clickstream and your search history on our Website.  

2 How do we use your personal data?

2.1          When you provide us with your information we will use it for the purpose of administering your query and responding to you. We therefore have legitimate interests in processing your personal data in this way, since if we do not process your data we will be unable to do this.  

2.2          We will not process your name and email address to send you marketing information unless we have your consent or other lawful basis for doing so. Any consent that you provide can be withdraw at any time by clicking "unsubscribe" on any marketing email we send to you, or emailing us at cliff@elevenadvisory.com  Withdrawing your consent does not affect the lawfulness of any processing which occurred prior to the withdrawal of consent.

2.3          We may also use your personal information:

2.3.1      to help us provide you with the best possible service;

2.3.2      to notify you about changes to the services we offer;

2.3.3     to ensure that the content from our Website is presented in the most effective manner for you and your computer;

2.3.4      as part of our efforts to keep our Website safe and secure; and

2.3.5      for analytical and statistical purposes.

3 Disclosure of Information

3.1          We will only supply your personal information to a third party:

3.1.1     where we need to share the information to provide a product or a service requested by you;

3.1.2     where we need to send the information to persons or organisations who work on our behalf to provide a product or service to you, but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose;

3.1.3     companies which perform marketing services on our behalf or with whom we have joint marketing agreements, where we have your consent or other lawful basis to share the information;

3.1.4     if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

3.1.5     if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our customers or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4 Where we store your information

4.1 The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out above only. In order to ensure that any third party treats your personal data in a way which is consistent with the UK and EU's laws on data protection, we have put in place agreements with those third parties which contain provisions approved by the EU for protecting personal data.

4.2          We will retain your information for six (6) years from the end of the relevant services provided to you and in compliance with our obligations under the GDPR (or similar legislation around the world) or as may be required under any legal or other applicable regulatory obligation, after which time it will be destroyed.

5 Links to other websites

5.1          This policy extends only to our Website and does not cover your use of, provision of data to and collection of your data on any other website.

5.2          Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to any third party website.

6 Your rights in respect of your information

You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

6.1          Your right of access

6.1.1     If you ask us, we’ll confirm whether we’re processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the GDPR for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.

6.2          Your right to rectification

6.2.1     If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

6.3          Your right to erasure

6.3.1     You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

6.4          Your right to restrict processing

6.4.1     You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

6.5          Your right to data portability

6.5.1     With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

6.6          Your right to object

6.6.1     You can ask us to stop processing your personal information, and we will do so, if we are:

(a)           relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

(b)          processing your personal information for direct marketing.

6.7          Your rights in relation to automated decision-making and profiling

6.7.1     You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

6.8          Your right to withdraw consent

6.8.1     If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

6.9          Your right to lodge a complaint with the supervisory authority

6.9.1     If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Information Commissioner’s Office (ICO) in the UK where your concern relates to Lewis Silkin LLP. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their office on 0303 123 1113.

7 Contact

If you have any questions, want to exercise any of your rights or make a complaint, please contact us at emailing us at cliff@elevenadvisory.com.

8 Changes to this privacy policy

This policy may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.