Privacy Policy
This policy explains how Ellington collects, uses, stores, and protects your personal data when you visit our website or use our services. Please read it carefully.
Who we are
The data controller responsible for your personal information under applicable data protection law.
Data Controller
Ellington Ltd (275 Slater St. #900, Ottawa, Ontario K1P 5H9, Canada) and ELLINGTON TRADE LTD (First Floor, First St. Vincent Bank Ltd Building, James Street, Kingstown, St. Vincent and the Grenadines) are the joint data controllers for personal data collected through this website and related services.
Scope
This Privacy Policy applies to all visitors of www.Ellingtonltd.com and any subdomains, as well as users of our educational and informational services. It covers the collection, processing, storage, transfer, and deletion of personal data.
Legal bases
We process personal data under the following legal bases as defined by applicable data protection regulations: (i) your explicit consent, (ii) the necessity of processing for the performance of a contract, (iii) compliance with a legal obligation, and (iv) our legitimate interests in operating and improving our website and services, provided those interests do not override your fundamental rights.
What we collect
The categories of personal data we may collect from you and how we collect them.
Information you provide
- Full name and contact details (email, phone, postal address)
- Company name and professional title
- Enquiry messages and correspondence
- Newsletter subscription preferences
- Feedback and survey responses
Information collected automatically
- IP address and browser type
- Device type and operating system
- Pages visited and time spent on each page
- Referring website URL
- Essential cookie data (see our Cookie Policy for details)
How we use your data
The purposes for which we process the personal data collected through this website.
Primary purposes
We use your personal data to: (i) respond to your enquiries and correspondence, (ii) provide you with the educational information and resources you request, (iii) send you relevant updates and newsletters where you have consented to receive them, (iv) improve and personalise your experience on our website, (v) comply with our legal and regulatory obligations, and (vi) detect, prevent, and investigate fraudulent or prohibited activity.
Marketing communications
We will only send you marketing communications where you have given your explicit consent. You may withdraw your consent or opt out at any time by clicking the unsubscribe link in any email or by contacting us directly at privacy@Ellingtonltd.com. We do not sell or rent your personal data to third parties for their own marketing purposes.
Automated decision-making
We do not engage in automated decision-making or profiling that produces legal effects concerning you or similarly significantly affects you. Should this change in the future, we will notify you and obtain any required consent before implementing such processing.
Who we share it with
Categories of third parties with whom we may share your personal data and why.
Service providers
- Web hosting and infrastructure providers
- Email delivery and newsletter platforms
- Analytics and website performance monitoring
- Customer relationship management tools
- Professional advisors (legal, accounting, compliance)
Regulatory & legal disclosures
- Regulatory authorities where required by applicable law
- Law enforcement agencies in response to lawful requests
- Courts or tribunals in connection with legal proceedings
- Auditors and compliance bodies as part of oversight
Data retention & security
How long we keep your data and the measures we take to protect it.
Retention periods
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. Generally, enquiry and correspondence data is retained for 24 months after the last communication. Where you have subscribed to our newsletter, we retain your data until you unsubscribe. Data retained for regulatory compliance purposes is kept for the duration required by applicable law.
Security measures
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These include encryption in transit (TLS 1.2+), access controls, regular security assessments, and staff training on data protection practices. Despite these measures, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
International transfers
Your personal data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, including Canada and St. Vincent and the Grenadines. Where such transfers occur, we ensure appropriate safeguards are in place, including standard contractual clauses or equivalent mechanisms recognised under applicable data protection law.
Your rights
The rights available to you under applicable data protection law and how to exercise them.
Your rights
Subject to applicable law, you have the right to: (i) request access to the personal data we hold about you, (ii) request rectification of inaccurate or incomplete data, (iii) request erasure of your data where there is no legitimate ground for continued processing, (iv) request restriction of processing in certain circumstances, (v) request data portability, (vi) object to processing based on legitimate interests or direct marketing, and (vii) withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
How to exercise your rights
To exercise any of these rights, please contact our Data Protection Officer at dpo@Ellingtonltd.com or write to us at 275 Slater St. #900, Ottawa, Ontario K1P 5H9, Canada. We will respond to your request within 30 days. If you are dissatisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.
Privacy enquiries
If you have any questions about this Privacy Policy or how we handle your data, please contact us.
Data Protection Officer
DPO, Ellington Ltd
275 Slater St. #900
Ottawa, Ontario K1P 5H9
Canada
Contact details
- Email: dpo@Ellingtonltd.com
- Phone: +1 (613) 800‑4240
- Web: www.Ellingtonltd.com
