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Privacy Policy

EELIS VIRTUAL ASSISTANTS LTD PRIVACY POLICY

Introduction

EELIS VIRTUAL ASSISTANTS LTD respects your privacy and is committed to protecting your

personal data. This privacy policy will inform you as to how we look after your personal data

when you visit our website (regardless of where you visit it from) and tell you about your

privacy rights and how the law protects you.

Please use the Glossary below to understand the meaning of some of the terms used in this

privacy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how EELIS VIRTUAL ASSISTANTS LTD

collects and processes your personal data through your use of this website, including any

data you may provide through this website when you sign up to our newsletter, request a

service or take part in a competition or apply to work with or for us.

This website is not intended for children and we do not knowingly collect data relating to

children.

It is important that you read this privacy policy together with any other privacy policy or fair

processing notice we may provide on specific occasions when we are collecting or

processing personal data about you so that you are fully aware of how and why we are using

your data. This privacy policy supplements the other notices and is not intended to override

them.

This privacy policy was last updated on 13/05.2025.

Controller

EELIS VIRTUAL ASSISTANTS LTD (Company registered number 13934966) is the controller

and responsible for your personal data (collectively referred to as “Eelis Virtual Assistants

Ltd“, “we”, “us” or “our” in this privacy policy).

We have appointed a GDPR owner who is responsible for overseeing questions in relation to

this privacy policy. If you have any questions about this privacy policy, including any

requests to exercise your legal rights, please contact the GDPR owner using the details set

out below.

Contact details

Our full details are:

Full name of legal entity: Eelis Virtual Assistants Ltd

Name or title of GDPR owner: Precious Mawire

Email address: hello@eelisva.co.uk

Postal address: Harborough Road, Kettering, NN14 2QY, UK

Telephone number: (+44) 7946044185

You have the right to make a complaint at any time to the Information Commissioner’s

Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We

would, however, appreciate the chance to deal with your concerns before you approach the

ICO so please contact us in the first instance.

ICO Contact details:-

Information Commissioner’s Office

Wycliffe House, Water Lane

Wilmslow, Cheshire

SK9 5AFTel: 0303 123 1113

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please

keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on

those links or enabling those connections may allow third parties to collect or share data

about you. We do not control these third-party websites and are not responsible for their

privacy statements. When you leave our website, we encourage you to read the privacy

policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from

which that person can be identified. It does not include data where the identity has been

removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we

have grouped together follows:

• Identity Data includes photographs of you, first name, maiden name, last name,

username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone

numbers.

• Employee/Contractor Specific Data includes the information not included in other

categories which we will collect from those who work for or with us including those

who apply to work for or with us such as recruitment information and employment

records

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details

of your contract with us and products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type

and version, time zone setting and location, browser plug-in types and versions,

operating system and platform and other technology on the devices you use to

access this website.

• Profile Data includes your username and password, purchases or orders made by

you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website and services.

• Marketing and Communications Data includes your preferences in receiving

marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for

any purpose. Aggregated Data may be derived from your personal data but is not

considered personal data in law as this data does not directly or indirectly reveal your

identity. For example, we may aggregate your Usage Data to calculate the percentage of

users accessing a specific website feature. However, if we combine or connect Aggregated

Data with your personal data so that it can directly or indirectly identify you, we treat the

combined data as personal data which will be used in accordance with this privacy policy.

Where it is specifically relevant to your contract with us and suitable safeguards have been

put in place, we may process Special Categories of Personal Data about you (this includes

details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual

orientation, political opinions, trade union membership, information about your health andgenetic and biometric data). We do not collect any information about criminal convictions

and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have

with you and you fail to provide that data when requested, we may not be able to perform

the contract we have or are trying to enter into with you (for example, to provide you with

goods or services or to employ or engage you). In this case, we may have to cancel a product

or service you have with us or we may not be able to employ or engage you but we will

notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Employee/Contractor

Specific Data and Financial Data by filling in forms or by corresponding with us by

post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey;

• give us some feedback;

• apply for a job with us; or

• work for or provide services to us.

• Automated technologies or interactions. As you interact with our website, we may

automatically collect Technical Data about your equipment, browsing actions and

patterns. We collect this personal data by using cookies, server logs and other similar

technologies.

• Third parties or publicly available sources. We may receive personal data about you

from various third parties and public sources as set out below:

• Technical Data from the following parties:

• analytics providers such as Google based outside the UK;

• advertising networks based inside or outside the UK; and

• search information providers based inside or outside the UK.

• Contact, Financial and Transaction Data from providers of technical, payment and

delivery services based inside or outside the UK and, where you have applied for a

job with us, from your former employer(s), employment agencies or background

check providers.

• Identity and Contact Data from recruitment or employment agencies, data brokers

or aggregators based inside or outside the UK.

• Identity and Contact Data from publicly availably sources such as Companies House

and the Electoral Register based inside the UK.

• Identity and Contact Data from social media platforms based outside the UK such as

Facebook.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use

your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered

into with you.• Where it is necessary for our legitimate interests (or those of a third party) and your

interests and fundamental rights do not override those interests. Please see the

Glossary for more details on legitimate interests.

• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other

than in relation to sending third party direct marketing communications to you via email or

text message. You have the right to withdraw consent to marketing at any time by

contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your

personal data, and which of the legal bases we rely on to do so. We have also identified

what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending

on the specific purpose for which we are using your data. Please contact us if you need

details about the specific legal ground we are relying on to process your personal data

where more than one ground has been set out in the table below.

Purpose/Activity Type of data (a) Identity

(b) Contact

(c) Employee/Contractor

Specific

(d) Financial

(e) Transaction

(f) Special Categories of

To employ you or engage you to carry out work for us

Data

(a) Identity

To register you as a new customer

(b) Contact (a) Identity

(b) Contact

(c) Financial

To process and deliver your order including:

(d) Transaction

(a) Manage payments, fees and charges

(e) Marketing and

(b) Collect and recover money owed to us

Communications

(a) Identity

(b) Contact

To manage our relationship with you which will include:

(c) Profile

(a) Notifying you about changes to our terms or privacy policy

(d) Marketing and

(b) Asking you to leave a review or take a survey

Communications

(a) Identity

To enable you to partake in a prize draw, competition or complete a

(b) Contact

survey

(c) Profile

Lawf

(a) Pe

(b) N

deter

(c) Ne

in the

safet

Perfo

(a) Pe

(b) N

(a) Pe

(b) N

(c) Ne

how

(a) Pe

(b) N

prod(d) Usage

(e) Marketing and

Communications

To administer and protect our business and this website (including

(a) Identity

troubleshooting, data analysis, testing, system maintenance,

(b) Contact

support, reporting and hosting of data)

(c) Technical

(a) Identity

(b) Contact

(c) Profile

(d) Usage

To deliver relevant website content and advertisements to you and

(e) Marketing and

measure or understand the effectiveness of the advertising we

Communications

serve to you

(f) Technical

To use data analytics to improve our website, products/services,

(a) Technical

marketing, customer relationships and experiences

(b) Usage

(a) Identity

(b) Contact

(c) Technical

To make suggestions and recommendations to you about goods or

(d) Usage

services that may be of interest to you

(e) Profile

Use of Special Categories of Data of employees/contractors

We do not need your consent if we use special categories of your personal information in

accordance with our written policy to carry out our legal obligations or exercise specific

rights in the field of employment law. In limited circumstances, we may approach you for

your written consent to allow us to process certain particularly sensitive data. If we do so,

we will provide you with full details of the information that we would like and the reason we

need it, so that you can carefully consider whether you wish to consent. You should be

aware that it is not a condition of your employment contract with us that you agree to any

request for consent from us.

Less commonly, we may use information relating to criminal convictions where it is

necessary in relation to legal claims, where it is necessary to protect your interests (or

someone else’s interests) and you are not capable of giving your consent, or where you

have already made the information public. We may only use information relating to criminal

convictions where the law allows us to do so. This will usually be where such processing is

necessary to carry out our obligations and provided we do so in line with our privacy policy.

We will only collect information about criminal convictions if it is appropriate given the

nature of the role and where we are legally able to do so.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly

around marketing and advertising.

(a) N

admi

a bus

(b) N

Nece

prod

strate

Nece

and s

infor

Nece

businPromotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on

what we think you may want or need, or what may be of interest to you. This is how we

decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from

us or services from us or if you provided us with your details when you entered a

competition or registered for a promotion and, in each case, you have not opted out of

receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any

company outside Viva Business & Lifestyle Ltd for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by

logging into the website and checking or unchecking relevant boxes to adjust your

marketing preferences or by following the opt-out links on any marketing message sent to

you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal

data provided to us as a result of a product/service purchase, warranty registration,

product/service experience or other transactions.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive.

Once you agree, the file is added and the cookie helps analyse web traffic or lets you know

when you visit a particular site. Cookies allow web applications to respond to you as an

individual. The web application can tailor its operations to your needs, likes and dislikes by

gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used and how the user interacts

with said page. This helps us analyse data about web page traffic and improve our website

in order to tailor it to customer needs. We only use this information for statistical analysis

purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which

pages you find useful and which you do not. A cookie in no way gives us access to your

computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept

cookies, but you can usually modify your browser setting to decline cookies if you prefer.

This may prevent you from taking full advantage of the website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we

reasonably consider that we need to use it for another reason and that reason is compatible

with the original purpose. If you wish to get an explanation as to how the processing for the

new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we

will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in

compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes

set out in the table in paragraph 4 above.• Internal Third Parties as set out in the Glossary.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our

business or our assets. Alternatively, we may seek to acquire other businesses or

merge with them. If a change happens to our business, then the new owners may

use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in

accordance with the law. We do not allow our third-party service providers to use your

personal data for their own purposes and only permit them to process your personal data

for specified purposes and in accordance with our instructions.

6. International transfers

Many of our external third parties are based outside the UK so their processing of your

personal data will potentially involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of

protection is afforded to it by ensuring at least one of the following safeguards is

implemented:

• We will only transfer your personal data to countries that have been deemed to

provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for

use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us

when transferring your personal data out of the UK.

We ensure your personal data is protected by requiring all our group companies to follow

the same rules when processing your personal data. These rules are called “binding

corporate rules”.

Data security

We have put in place appropriate security measures to prevent your personal data from

being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In

addition, we limit access to your personal data to those employees, agents, contractors and

other third parties who have a business need to know. They will only process your personal

data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will

notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we

collected it for, including for the purposes of satisfying any legal, accounting, or reporting

requirements.

To determine the appropriate retention period for personal data, we consider the amount,

nature, and sensitivity of the personal data, the potential risk of harm from unauthorised

use or disclosure of your personal data, the purposes for which we process your personal

data and whether we can achieve those purposes through other means, and the applicable

legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity,

Financial and Transaction Data) for six years after they cease being customers for tax

purposes.In some circumstances you can ask us to delete your data: see Request erasure below for

further information.

In some circumstances we may anonymise your personal data (so that it can no longer be

associated with you) for research or statistical purposes in which case we may use this

information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your

personal data. Please see below to find out more about these rights.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other

rights). However, we may charge a reasonable fee if your request is clearly unfounded,

repetitive or excessive. Alternatively, we may refuse to comply with your request in these

circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and

ensure your right to access your personal data (or to exercise any of your other rights). This

is a security measure to ensure that personal data is not disclosed to any person who has no

right to receive it. We may also contact you to ask you for further information in relation to

your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us

longer than a month if your request is particularly complex or you have made a number of

requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our

business to enable us to give you the best service/product and the best and most secure

experience. We make sure we consider and balance any potential impact on you (both

positive and negative) and your rights before we process your personal data for our

legitimate interests. We do not use your personal data for activities where our interests are

overridden by the impact on you (unless we have your consent or are otherwise required or

permitted to by law). You can obtain further information about how we assess our

legitimate interests against any potential impact on you in respect of specific activities by

contacting us

Performance of Contract means processing your data where it is necessary for the

performance of a contract to which you are a party or to take steps at your request before

entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it

is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Our sub-contractors who we use specifically for the purpose of performing the

services we provide to you under our agreement.

• Service providers based in USA, EU and Canada who provide IT, Accounting software,

data storage, communication mail outs.

• Partners and affiliates.• Professional advisers acting as processors or joint controllers including lawyers,

bankers, auditors and insurers based in the United Kingdom who provide

consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or

joint controllers based in the United Kingdom who require reporting of processing

activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”).

This enables you to receive a copy of the personal data we hold about you and to check that

we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have

any incomplete or inaccurate data we hold about you corrected, though we may need to

verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove

personal data where there is no good reason for us continuing to process it. You also have

the right to ask us to delete or remove your personal data where you have successfully

exercised your right to object to processing (see below), where we may have processed your

information unlawfully or where we are required to erase your personal data to comply with

local law. Note, however, that we may not always be able to comply with your request of

erasure for specific legal reasons which will be notified to you, if applicable, at the time of

your request.

Object to processing of your personal data where we are relying on a legitimate interest (or

those of a third party) and there is something about your particular situation which makes

you want to object to processing on this ground as you feel it impacts on your fundamental

rights and freedoms. You also have the right to object where we are processing your

personal data for direct marketing purposes. In some cases, we may demonstrate that we

have compelling legitimate grounds to process your information which override your rights

and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to

suspend the processing of your personal data in the following scenarios: (a) if you want us

to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not

want us to erase it; (c) where you need us to hold the data even if we no longer require it as

you need it to establish, exercise or defend legal claims; or (d) you have objected to our use

of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to

you, or a third party you have chosen, your personal data in a structured, commonly used,

machine-readable format. Note that this right only applies to automated information which

you initially provided consent for us to use or where we used the information to perform a

contract with you.

Withdraw consent at any time where we are relying on consent to process your personal

data. However, this will not affect the lawfulness of any processing carried out before you

withdraw your consent. If you withdraw your consent, we may not be able to provide

certain products or services to you. We will advise you if this is the case at the time you

withdraw your consent.


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