We at ELV Environmental Services CLG respect your right to privacy and treat any personal data which you submit to this Site or to us as an organisation in accordance with our obligations under the General Data Protection Regulation (GDPR) and the Data Protection Acts 1988 to 2018. The purpose of this Privacy Statement is to outline how we deal with any personal data you provide to us, this includes through our websites www.elves.ie or www.electricelves.ie and any webpages containing these domain names (our "Site"), via email, in person (for example at an event) or through publicly available information.
Naturally, if you are not happy with this Privacy Statement you should not use our Site. By visiting our Site, you are accepting the terms of this Privacy Statement. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
References to "we", "us" or “ELVES” are to ELV Environmental Services CLG, a company limited by guarantee with a registered address at 38, Upper Mount Street, Dublin 2 registered company 541351.
References to "you" or "your" shall refer to the users of our Site, those that interact with us via social media, or those we hold personal or non-personal data of.
Types of Information Collected
We collect and retain two types of information:
"Non-Personal Data": Non-Personal Data": Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, general geographic location, browser types and other statistical data involving the use of our website.
"Personal Data": Data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses in circumstances where this information has not been deleted, clipped or anonymised and telephone number. Such information is only collected from you on this Site if you voluntarily submit it to us.
Purposes for which we hold your information and timeframe held
Non-Personal Data: We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website. We use Google Analytics to do this.
Personal Data: We will process any Personal Data you provide to us for the following purposes:
- Personal data sent to us via our contact form.
If you send us an email using our Contact Us page, we will hold the personal data contained in this correspondence for the purposes of responding to your email. We will hold this data on the basis of our legitimate interest in operating as the compliance scheme for the sector delivering on our public awareness and education objectives. We will delete this personal data after 1 year. If you are contacting us from an Authorised Treatment Facility or are contacting us as a Producer, the ‘Personal data submitted or made available on Authorised Treatment Facilities’ or ‘Personal data provided as part of a Producer membership application’ applies.
- Personal data sent to us via ATF ratings.
If you submit an ATF Rating through the ATF page, we will hold the personal data contained in this correspondence for the purposes of verifying the rating submitted. We will hold this data on the basis of legitimate interest in operating as the compliance scheme for the sector providing improvement feedback to ATFs in our Network and will this delete personal data after 1 year.
- Personal data provided as part of a competition entry
In the event that you provide us with personal details as part of a competition run by ELVES (on social media, at an event or via our website) we hold this data on the basis of legitimate interest in operating as the compliance scheme for the sector delivering on our public awareness and education objectives. We use the information to administer the competition and contact winners.
For manual (paper) entries to competition at events, for non-winning entries, we dispose of these securely, once we have successfully contacted the winning entry. For the winning entry, we keep your personal details until we have confirmed you have received your prize. With your additional consent we may also use your image/name on social media to report on the competition.
For competitions run via our social media channels entries are retained within the social media channel as part of the competition post. We use Fanpage Karma Good Luck Fairy to select winners. Fanpage Karma has access to the personal data within the social media competition entries to select the winner, but does not retain this information. You can see their full Privacy Statement here https://www.fanpagekarma.com/privacy.
For Colouring Competitions we run, entries are made by parents/caregivers. Data collected on the children participating is kept to a minimum, with only the first names of the winning children shared via our social media and website.
ELVES may provide access to the personal data from competitions to third party contractors that help administer competitions and/or our social media channels. In such instances they are required to act in accordance with ELVES GDPR data policies.
- Personal data submitted to us under the Electric ELVES programme
Under the Electric ELVES programme you may submit personal data to us, for example a contact name or email address of someone at your site. We will use this personal data for the purposes of administering the programme and will hold it on the basis of legitimate interest in operating the Electric ELVES programme until we are able to confirm the handling and end destination of the battery concerned. We may share this data with the Producer of the vehicle to aid management of the battery. We will retain the name of your site for the period ELVES has approval to operate as the compliance scheme for the sector.
If you choose to sign up for a training course, participant data will be used by ELVES to register people on the course, assess uptake and participant progress. Data will also be provided to the course provider, to enable them to provide the training to you and a third party contractor, who provides administrative support to the programme. All data is held for one year after the training course, and then minimised to name of participant, employer and the waiver release form. These are held for the period ELVES has approval to operate as the compliance scheme for the sector.
- Personal data submitted to us under the F-Gas Pilot Project
If you choose to sign up for a MAC training course, participant data will be used by ELVES to register people on the course, assess uptake and participant progress. Data will also be provided to the course provider, to enable them to provide the training to you. We hold this data on the basis of legitimate interest in operating as the compliance scheme for the sector. This data is held for the period ELVES has approval to operate as the compliance scheme for the sector.
- Personal data provided as part of a Producer membership application
You may submit personal data to us as part of an application for Producer membership of ELVES. We hold this data on the basis of compliance with legal obligations and will hold the data for as long as we have approval to operate as the compliance scheme for the sector. As per our legal obligations, we may share this data with the Department of Environment, Climate Action and Communications, the Waste Enforcement Regional Local Authorities (WERLAs) and local authorities as required.
- Personal data submitted or made available on Authorised Treatment Facilities
Non-Network ATFs: We hold data on waste sites that have had or have a Waste Permit to operate as an ATF. The data is sourced from the publicly searchable databases on sites with Waste Facility Permits but may also contain additional data when submitted to us by an ATF. We hold this data on the basis of legitimate interest in operating as the compliance scheme for the sector and use it to understand which sites have permits and to contact sites in relation to ELVES activities of benefit to all ATFs (for example the Electric ELVES programme). This data is held for the period ELVES has approval to operate as the compliance scheme for the sector.
ATFs in the ELVES Network: Personal data from ATFs in the ELVES Network is held on the basis of contractual necessity. It is used to facilitate our interactions with ATFs in the Network as well as to promote them via our website. This data is held for the period ELVES has approval to operate as the compliance scheme for the sector. For ATFs that request it, we use their personal data to register them with the International Dismantling Information System (IDIS). We are joint controllers of this data with IDIS (www.idis2.com).
- Personal data provided through interactions with our social media channels
Through interacting with one of our social media channels (Facebook, Instagram, Twitter, YouTube) you make available to us personal data. ELVES is not the controller of the data contained on these social media channels.
ELVES uses Zoho Social, a social media management application to manage social media posts. You can read more about their GDPR compliance here: https://www.zoho.com/gdpr.html
Disclosure of information to third parties:
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our Site. For example, we might inform third parties regarding the number of unique users who visit our Site, the demographic breakdown of our community users of our Site, or the activities that visitors to our Site engage in while on our Site. The third parties to whom we may provide this information may include Government Departments, commercial partners, researchers and other similar parties.
We may disclose your Personal Data to third parties where you have consented to such disclosure or if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
In some circumstances, it may be necessary for us to process or transfer your Personal Data outside of the European Economic Area (EEA) for the purposes described in this Privacy Statement. We comply with applicable data protection law when doing so, such as by ensuring that the country or territory where your Personal Data will be processed is deemed by the European Commission to have an adequate level of protection for personal data.
Sale of business
We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Privacy Statement and provided that the third party only uses your Personal Data for the purposes that you provided it to us.
Your personal data is held on secure servers hosted by Key Elements. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data, in accordance with our obligations under the GDPR.
Changes to the Website Privacy Statement
Any changes to this Privacy Statement will be posted on this Site so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Statement, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner specified.
You have several rights under data protection law in relation to your personal information. In certain circumstances, you have the right, free of charge, to:
- request a copy of the Personal Data we hold about you
- rectify any inaccurate Personal Data we hold about you
- erase Personal Data we hold about you
- restriction of processing of your Personal Data
- object to our use of your Personal Data for our legitimate interests
- receive your Personal Data in a structured, commonly used and machine readable format and to have that Personal Data transmitted to another data controller.
These rights are in some circumstances limited by data protection legislation.
If you provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure we no longer process your Personal Data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.
If you wish to exercise any of these rights please contact us at email@example.com or ELV Environmental Services CLG, Unit 15-4, Workspace Centre, Mayoralty Street, Drogheda, Co. Louth, A92 E368. We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why.
You also have the right to lodge a complaint to the Data Protection Commission, the Irish supervisory authority for data protection issues (www.dataprotection.ie).