Privacy Policy
1. INTRODUCTION
This Privacy Policy (“Policy”) outlines what Personal Data is collected by Ela Expeditions Ltd. UK and Ela Expeditions Ltd. IE or any other entity doing business as Floodlight (“Company”, “we”, “us” or “our”), how we use such Personal Data, the choices you have with respect to such Personal Data, and other important information.
We keep your Personal Data personal and private. We will not sell, rent, share, or otherwise disclose your Personal Data to anyone except as necessary to provide our services or as otherwise described in this Policy.
"Personal Data" shall mean any data that can or may be used whether alone or in combination with other information in order to identify a single person, including the personal data processed on behalf of the Company’s clients.
2. FROM WHOM WE COLLECT PERSONAL DATA?
This Policy applies to Company's collection, use, and disclosure of the Personal Data of the following categories of individuals:
- who visit our Websites and who may volunteer certain contact data (such as their email address) to receive communications from us. For the purposes of this Policy, “Websites” shall refer collectively to https://www.joinfloodlight.com/"https://www.joinfloodlight.com/ as well as any other websites we own and that link to this Policy. For clarity, “Websites” does not include any sites owned or operated by our Customers.
- who register on their own or on behalf of an entity or organization to use any of the Services (as defined below), including administrators on a Customer account. For the purposes of this Policy, “Services” shall refer to all products or service offerings made available by us, including our Websites.
This Policy does not apply to our Customers’ websites, which may have their own terms and privacy policies. Our Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, including those relating to the collection of Personal Data in connection with the use of our Services by End Users with whom our Customers interact.
3. NOTE FOR MINORS
We do not knowingly collect or solicit Personal Data from anyone under the permitted age (as determined under the applicable laws where the individual resides) (“Permitted Age”). By accessing, using or interacting with our Websites or Services, you certify to us that you are not under the Permitted Age. In the event that we learn that we have collected Personal Data from an individual under the Permitted Age without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Permitted Age, then please contact us through the contact details available below.
4. WHAT PERSONAL DATA WE COLLECT?
- Name, email address, and other contact information. We ask for and—at your option—collect your contact data (such as name, company name and website, and email address) from you when you submit web forms on our Websites, including joining our waitlist and opportunities to sign up for and agree to receive email communications from us. We may also ask you to submit such Personal Data if you choose to use interactive features of the Websites, including participation in surveys, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.
- Log Files. When you visit our Websites, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences which can become Personal Data if combined with other identifiable information.
- Customer Account Information. When you open a customer account, we collect your email address and other contact data (such as your name and phone number). We will also ask you to enter your website domain in order to receive the Services. During the onboarding process, we will also require customers to provide identifying information about each beneficial owner of the customer, for our KYC and AML processes, including date of birth, phone number, nationality, country of residence, personal identity number, government issued ID, picture, and contact details.
- Payment Information. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address, although we do not store full credit card numbers or personal account numbers.
- Financial Information. When you are using the Services, you will be sharing with us your financial information as accessed via 3rd party websites (API aggregators). Such information includes your bank account details, balance, date and volume of transactions, and names of beneficiaries.
- We refer to these information categories as “Customer Information” for the purposes of this Policy. Customer Information is required to identify you as a Customer and permit you to access your account(s) and use our Services. By voluntarily providing us with such Customer Information, you represent that you are the owner of such Personal Data or otherwise have the requisite consent to provide it to us. To the extent Customer Information contains Personal Data relating to other data subjects, you have obtained the requisite consents to provide such Personal Data to us.
5. LEGAL BASIS FOR PROCESSING (EEA ONLY):
If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your Personal Data will depend on the Personal Data collected and the specific context in which we collect it.
This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.
Provision of our Services; support.
Purpose
We use your Personal Data, such as your name and email address, for consumer services purposes. This includes, for example, responding to your inquiries.
Legal basis
The legal basis for processing this data is the performance of our contractual obligations towards you; compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.
Financial Information.
Purpose
With your consent, we collect information from open banking platforms about your financial accounts and money management for the purpose of presenting you a single dashboard and provide our Services.
Legal basis
The legal bases for processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.
Payments.
Purpose
We collect from our third-party payment processors certain information about your payment instruments for the purpose of connecting your payment instrument to your account on our Services, and sending to you statements, invoices, and payment reminders.
Legal basis
The legal bases for processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.
KYC/AML Information.
Purpose
We collect from third parties Personal Data about you for compliance with financial regulations.
Legal basis
The legal bases for processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.
Improve our Services.
Purpose
We collect and analyse information about you and your usage of our Services to improve the usability and effectiveness of our Services.
Legal basis
The legal bases for processing this data are our legitimate interests, in this case – providing and improving our Services.
Marketing and Advertising.
Purpose
We may use Tracking Technologies (which may collect Personal Data) in order to provide you with personalized advertisements when you visit our Services.
Legal basis
The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests.
Integrity.
Purpose
We may process certain information about you and your use usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.
Legal basis
The legal bases for processing this data are your consent (where required), compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services and the safety of our end-users.
Compliance with applicable laws.
Legal basis
We may be required to collect, retain, or share your Personal Data, under applicable laws.
6. HOW WE USE PERSONAL DATA WE COLLECT?
We only processes Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we collect (including Personal Data, to the extent applicable) to:
- provide, operate, maintain, improve, and promote the Website and Services;
- enable you to access and use the Website and Services;
- process and complete transactions, and send you related information, including purchase confirmations and invoices;
- send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
- send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners. See Section 8 below for information on managing your communication preferences.
- monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
- comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
- personalize the Websites and Services, including by providing features or content that match your interests and preferences; and
- process for other purposes for which we obtain your consent.
7. HOW WE SHARE YOUR PERSONAL DATA?
We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as open banking provides, data enrichment providers, cloud storage companies), deliver customer support, deliver the functionality of our Services and Website, process debit card payments, monitor and analyze the performance of our Services and Websites, manage and contact our existing Customers as well as sales leads, provide marketing support, provide fraud prevention services, and otherwise operate and improve our Services. These Service Providers may only process Personal Data pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations.
Specifically, we do not permit our Service Providers to use any Personal Data we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:
- With other subsidiaries or affiliate companies of the Company;
- With our resellers and other sales partners and with marketing platforms (Google, Meta) who may help us distribute or promote the Services to Customers;
- In the event of a merger, sale, change in control, or reorganization of all our part of our business;
- With our auditors, advisers and potential investors of the Company;
- When we are required to disclose Personal Data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
- Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or
- as you may otherwise consent from time to time.
8. INTERNATIONAL INFORMATION TRANSFERS
Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your Personal Data) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy. Please note that some data recipients may be located outside the European Economic Area (the “EEA”). In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.
Whenever the Company shares Personal Data originating in the EEA, Switzerland or the UK with a Company entity outside the EEA, Switzerland or the UK, it will do so on the basis of the EU standard contractual clauses or the other applicable frameworks.
9. DATA SUBJECT RIGHTS
If you reside in the EU (or in other jurisdiction that affords you with the below rights), you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with certain supplementary information.
- Receive Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You also have a right to lodge a complaint with a supervisory authority
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the contact information listed below.
10. RETENTION
We will retain your Personal Data for up to six years or for as long as necessary to operate our Websites or provide Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
11. DATA SECURITY
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data.
While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services or Websites, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the Personal Data you choose to disclose.
12. CHANGES TO OUR PRIVACY POLICY
We reserve the right to change this Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Policy through our Website or we will send you an e-mail regarding such changes to the e-mail address that you volunteered (if you have volunteered it). Such substantial changes will take effect seven (7) days after such notice was provided on any of the above mentioned methods. Otherwise, all other changes to this Policy are effective as of the stated “Last Updated” date, and your continued use of the Websites or Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
13. BUSINESS TRANSACTIONS
We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.
14. CONTACT INFORMATION
In the UK
Ela Expeditions UK Limited
30 Old Bailey, London, EC4m 7JZ, United Kingdom
In the EEA
Ela Expeditions IE Limited
Block 3, Harcourt Centre, Harcourt Road, Dublin 2, D02 A339, Ireland
EC4M 7JZ
United Kingdom