Elucidate GmbH, located in Berlin, Germany, registered in: Amtsgericht Charlottenburg HRB 196707B, is the controller and responsible for your personal data (later referred throughout this document as “Elucidate”, “we”, “us” or “our”).
In some instances, Elucidate will take the role of data processor. Both roles – controller and/or processor – will be carried out in pursuant of GDPR and EU-Regulations, where different obligations will apply according to each role.
We collect and process personal data relating to visitors to efi.elucidate.co and elucidate.co in relation to the services we provide. The data we process differs depending on the different interactions with us, as detailed below.
This privacy policy sets out to give you information on:
Third-party links
This website includes links to third-party websites, plug-ins and applications. Upon clicking on those links, you will be redirected to a third-party website where our privacy policy no longer applies.
The information we collect varies in line with the use cases below:
| Data from website visitors to Elucidate.co regarding site usage, including IP addresses and browser versions used | Data collected through website cookies |
| Personal data from job candidates | Provided directly by any job candidate, collected through the elucidate.co website |
| Personal client data and information | Provided directly by our clients through and in accordance to contractual agreements. |
| Publicly available information relevant to the Elucidate FinCrime Index (“EFI”) | Public search |
| Business contacts, contact information or any publicly available data regarding a position in a company | Provided directly by business contacts |
| Data from website visitors | Used for marketing purposes and to ensure a correct usage of our website |
| Personal data from job candidates | Collected with the purpose of assessing the applicant’s suitability for a role |
| Personal client data and information | Collected for the express purpose of producing the Elucidate FinCrime Index (“EFI”) |
| Publicly available information | Collected for the express purpose of producing the Elucidate FinCrime Index (“EFI”) and adverse media sentiment analysis |
| Business contacts | To maintain business communications |
Information which has been gathered is available to selected parties as detailed below:
| Data from website visitors | Elucidates uses Matomo as a web analytics platform, which provides the option to host all data within Elucidate’s secure cloud infrastructure. Data is only available to our marketing team |
| Personal data from job candidates | Store in an externally provided HR system, to which only selected Elucidate employees have access in order to determine candidate suitability |
| Personal client data and information | Encrypted, to which only selected Elucidate employees have access to, on an as-needed basis |
| Business contacts | Externally provided CRM application is accessible only by Elucidate employees, specifically sales, marketing and client success team |
Our data processing centre and our backup data centre are located in Frankfurt am Main in Germany. We have configured the data centres to store data within the EU only.
In all cases, we strive to ensure that data remains within the EU/EEA and select our sub-processors with that in mind. In such exceptional cases where a sub-processor stores data outside the EU/EEA, the selected sub-processor is required to provide the suite of GDPR protections to such data.
The sub-processors list is available under the following link: https://elucidate.co/sub-processors.
| Data from website visitors | Until the cookie expiration date |
| Personal data from job candidates | For unsuccessful candidates, data will be removed after 6 months. Successful candidates’ information becomes subject to our employee privacy policy |
| Personal client data and information | Information is retained subject to the conditions outlined in the contract in accordance with GDPR and EU-Regulations |
| Business contacts | Email marketing has unsubscribe functionalities. Information in our CRM is categorised by activity and inactive data is removed after a period of 5 years, or unless specifically requested by an individual. You can ask for removal by sending an email to dpo@elucidate.co. |
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology
For further information, visit allaboutcookies.org.
Types of cookies and how do we use them
Elucidate uses:
| Functionality | To recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used |
| Advertising | To collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address |
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Elucidate would like to make sure you are fully aware of all of your data protection rights. In accordance with GDPR, we commit to handling your data in a transparent manner. Every user is entitled to the following:
| The right to access | You have the right to request copies of your personal data |
| The right to rectification | You have the right to request that Elucidate correct any information you believe is inaccurate. You also have the right to request to complete the information you believe is incomplete |
| The right to erasure | You have the right to request the erasure of your personal data, under certain conditions subject to EU-Regulations (eg. REGULATION (EU) 2016/1011) |
| The right to restrict processing | You have the right to request that we restrict the processing of your personal data, under certain conditions |
| The right to object to processing | You have the right to object to our processing of your personal data, under certain conditions |
| The right to data portability | You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions |
You can always contact the DPO regarding GDPR issues, regardless of Elucidate’s role as processor or controller, via email to dpo@elucidate.co.
If there is a concern regarding the proper handling of personal data, a complaint can be made to our data protection regulator, the German Information Commissioner’s Office or in Berlin.
We rely on contractual and legal obligations in order to handle all data and collect it lawfully. We ensure to protect the legitimate interest of all parties and to act according to the principle of transparency.
Elucidate is a regulated benchmark and therefore subjected not only to GDPR but to other EU-Regulations (eg. REGULATION (EU) 2016/1011). According to EU-Law we are obliged to retain all data exclusively related to the process of generating and providing the Elucidate FinCrime Index (“EFI”) platform for 5 years before deleting it.
Data from website visitors, personal data from job candidates and business contacts do not fall into this category and are handled separately according to GDPR regulations.
